J. Jacob v. Bureau of Driver Licensing

CourtCommonwealth Court of Pennsylvania
DecidedMarch 17, 2025
Docket198 C.D. 2024
StatusUnpublished

This text of J. Jacob v. Bureau of Driver Licensing (J. Jacob v. Bureau of Driver Licensing) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J. Jacob v. Bureau of Driver Licensing, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Jeffrey Jacob, : Appellant : : v. : : Commonwealth of Pennsylvania, : Department of Transportation, : No. 198 C.D. 2024 Bureau of Driver Licensing : Argued: December 9, 2024

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge (P.) HONORABLE MARY HANNAH LEAVITT, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE FIZZANO CANNON FILED: March 17, 2025

Jeffrey Jacob (Jacob) appeals from the November 22, 2023, and January 25, 2024, orders of the Court of Common Pleas of Luzerne County (trial court). The trial court’s orders upheld a lifetime disqualification of Jacob’s commercial driver’s license (CDL) pursuant to the Uniform Commercial Driver’s License Act (CDL Act), 75 Pa.C.S. §§ 1601-1622, which is within the Vehicle Code, 75 Pa.C.S. §§ 101-9910, because Jacob has two convictions for driving under the influence of alcohol (DUI). Upon review, we affirm.

I. Factual & Procedural Background Jacob received his CDL in 1997; committed a DUI offense in July 2011 that was resolved via accelerated rehabilitation disposition (ARD) and resulted in a one-year suspension of his CDL; and then committed a second DUI offense in November 2022, of which he was convicted in August 2023. Reproduced Record (R.R.) at 48a-51a. On August 23, 2023, the Department of Transportation, Bureau of Driver Licensing (DOT) sent Jacob a letter stating that due to his conviction for the November 2022, DUI offense, which was his second DUI conviction, he would be disqualified for life from holding a CDL pursuant to Section 1611(c) of the CDL Act, 75 Pa.C.S. § 1611(c). Id. at 7a. For the same incident, Jacob was also subject to a one-year suspension of his personal driver’s license. Id. at 4a. Jacob timely filed a petition for appeal and a supporting brief with the trial court. R.R. at 11a-19a. Jacob asserted that imposition of a lifetime CDL disqualification was in error, illegal, unreasonable, an abuse of discretion, and did not comply with the requirements of the Vehicle Code “and the Constitution of Pennsylvania and United States.” Id. at 12a & 17a. Specifically, he stated that he “has not been convicted of two or more violations of any of the offenses” that would trigger a lifetime CDL disqualification and that because lifetime CDL disqualification would cause him “great hardship and inconvenience,” mitigation was warranted. Id. at 13a & 17a. An initial hearing was held on November 13, 2023, on both the one- year suspension of Jacob’s personal license and the lifetime disqualification of his CDL. R.R. at 28a. The DOT introduced Jacob’s certified driving history, including his July 2011 and November 2022 DUI convictions. Id. at 29a. Jacob’s counsel acknowledged the DUI dispositions and stated that he planned to present legal argument at that time because “I don’t think much of the factual predicate is in dispute.” R.R. at 29a. Jacob’s counsel noted that the “the argument from our side is particularly in light of the whole legal discussion about whether or not a DUI resolved via ARD counts as a prior conviction. Our position on it is that it does not

2 and, therefore, the lifetime ban does not apply.” Id. He added that “the courts have gone back and forth” on whether, in the criminal context, including a DUI resolved via ARD as a “prior offense” violated due process because the DOT did not have to prove guilt beyond a reasonable doubt and that “until the Supreme Court resolves the issue,” Jacob should not be subject to lifetime CDL disqualification. Id. Jacob’s counsel added that mitigation to a ten-year suspension was warranted because Jacob works for the public works department and his livelihood “is very much contingent upon him maintaining a CDL.” Id. The trial court subsequently issued a November 23, 2023, order upholding the one-year suspension of Jacob’s personal driver’s license, which is not at issue here, and scheduling an evidentiary hearing on the lifetime disqualification of his CDL. R.R. at 54a. At the January 2024 hearing, the DOT argued that under Dietrich v. Department of Transportation, Bureau of Driver Licensing, 82 A.3d 1087 (Pa. Cmwlth. 2013), the trial court had no authority or discretion to mitigate Jacob’s lifetime CDL disqualification because although the statutory scheme authorized the DOT to enact mitigation guidelines, the DOT had not done so, and there was no statutory basis for the trial court to devise an equitable remedy in a particular case. R.R. at 55a-56a. Jacob’s counsel countered that under Sondergaard v. Department of Transportation, Bureau of Driver Licensing, 65 A.3d 994 (Pa. Cmwlth. 2013), lifetime CDL disqualification is penal in nature and that because the CDL Act is within the Vehicle Code (Chapter 16), and Section 1611(c) imposes a penal consequence, that provision is equivalent to certain criminal DUI sentencing provisions in Chapter 38 of the Vehicle Code that are currently on appeal in our

3 courts. R.R. at 57a. Jacob’s counsel further pointed to our Supreme Court’s pending review in Commonwealth v. Richards, 294 A.3d 300 (Pa. 2023). The issue in Richards is whether a previous DUI offense resolved via ARD is a “prior offense” under Section 3806 of the Vehicle Code, 75 Pa.C.S. § 3806, which pertains to criminal DUI penalties such as probation, fines, and prison sentences. Jacob’s counsel posited that if our Supreme Court ultimately finds it unconstitutional to count a previous DUI offense resolved via ARD as a “prior offense” for criminal penalties on the basis that in the ARD context, the Commonwealth does not have to establish guilt beyond a reasonable doubt, then it should likewise be unconstitutional to count a previous DUI offense resolved through ARD as a prior conviction for purposes of Section 1611(c) of the CDL Act, even though lifetime CDL disqualification is a civil penalty: “it’s the horse with the same colors.” R.R. at 57a. At the end of the January 2024 hearing, the trial court stated that even though the hearing had been called for mitigation evidence on Jacob’s lifetime CDL disqualification, because it had no authority to reduce or mitigate the penalty regardless of what evidence might have been presented, the matter would be dismissed. R.R. at 58a. The trial court subsequently issued its January 25, 2024, final order stating that pursuant to Dietrich, it lacked jurisdiction to reduce Jacob’s lifetime CDL disqualification and reiterated that Jacob’s appeal was dismissed. Id. at 66a. Jacob timely appealed to this Court. His statement pursuant to Pennsylvania Rule of Appellate Procedure 1925(b), Pa.R.A.P. 1925(b), framed his issues as follows: [The DOT] failed to meet its burden of establishing [that Jacob] was convicted of two or more violations of any of the offenses specified in [Section] 1611(a) within the meaning of [Section] 1611(c).

4 Section 1611(c) violates the federal and Pennsylvania constitutional prohibitions on cruel and unusual punishment.

R.R. at 71a-76a. In his Rule 1925(b) statement, Jacob did not specifically reiterate his statutory argument from the January 2024 hearing based on Section 3806(a) of the Vehicle Code, 75 Pa.C.S. § 3806(a), specifically that because his first DUI was resolved via ARD and the Commonwealth did not have to establish his guilt beyond a reasonable doubt, it is not a valid prior conviction for purposes of lifetime CDL disqualification pursuant to Section 1611(c) of the CDL Act. Instead, Jacob asserted that Section 3806(b) of the Vehicle Code, 75 Pa.C.S.

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Bluebook (online)
J. Jacob v. Bureau of Driver Licensing, Counsel Stack Legal Research, https://law.counselstack.com/opinion/j-jacob-v-bureau-of-driver-licensing-pacommwct-2025.