McCrea v. PennDOT

14 Pa. D. & C.4th 43, 1992 Pa. Dist. & Cnty. Dec. LEXIS 341
CourtPennsylvania Court of Common Pleas, Franklin County
DecidedJanuary 24, 1992
StatusPublished

This text of 14 Pa. D. & C.4th 43 (McCrea v. PennDOT) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Franklin County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McCrea v. PennDOT, 14 Pa. D. & C.4th 43, 1992 Pa. Dist. & Cnty. Dec. LEXIS 341 (Pa. Super. Ct. 1992).

Opinion

KELLER, P.J.,

FINDINGS OF FACT

(1) McCrea permitted his liability insurance coverage provided by General Accident Insurance Co. to lapse on May 21, 1991, because he could not afford to pay the premium.

(2) McCrea on or before May 21, 1991, parked his vehicle and did not thereafter operate it on any public roads or allow anyone else to operate it during the period of time the vehicle was not covered by liability insurance. He did move it from place to place in his own yard, and he did make various repairs to the vehicle during that time period.

(3) McCrea secured liability insurance coverage for the vehicle with Erie Insurance Co. on June 28, 1991, and since that date has operated the vehicle. To the best of his knowledge Erie Insurance Co. did send proof of insurance coverage to DOT.

[44]*44(4) McCrea did not know his registration privilege was subject to being suspended for three months when he allowed his insurance to lapse. He also did not know there was a 21-day limit on reinstating insurance. He testified that had he known of the 21-day limit and the possibility of registration suspension, he would have surrendered his registration card and license plate to DOT at the time his insurance coverage terminated: all as provided in 75 Pa.C.S. §1786(g)(2).

(5) McCrea moved from 30 E. 3rd Street, Waynesboro, Pennsylvania to 238 Wayne Avenue, Waynesboro, Pennsylvania during the month of January 1991, but did not notify DOT of the move until Saturday, December 17, 1991.

(6) McCrea did not attempt to reply to the official notice of August 27,1991, except by filing his petition for appeal and supersedeas.

(7) McCrea conceded that it is possible some other person could have driven his vehicle while it was uninsured, but he knew of no one who had done so.

DISCUSSION

The appellant’s insurance carrier terminated his automobile insurance on May 21,1991. By official notice dated August 27, 1991, the Pennsylvania Department of Transportation, informed the appellant as follows:

“You were recently requested to provide proof of financial responsibility covering the operation of the described motor vehicle. This information was requested as a result of this bureau being notified by General Accident Insurance Co. of America that the insurance policy covering the vehicle terminated on May 21, 1991. Either no response was received or [45]*45the information you provided indicated a lapse in coverage in excess of 21 days.

“To Prevent Suspension:

“Submit a copy of your insurance identification card, the declaration page of your insurance policy, a valid binder of insurance, or an application for insurance to the Pennsylvania Auto Insurance Plan as evidence that the described motor vehicle was continuously covered by liability insurance. However, if there was a lapse in insurance coverage, you must provide this bureau with proof of insurance indicating an effective date of coverage of 21 days or less from May 21, 1991, and also provide an affidavit stating that the vehicle was not operated during this time. It is necessary for you to provide copies of the insurance documents and return with this notification. A self-addressed label is enclosed for your convenience.

“Please Note: Original Documents Will Not Be Returned.

“If You Cannot Comply With These Instructions:

“(1) Your registration privilege will be suspended for three months effective October 1, 1991, at 12:01 a.m. as authorized by section 1876(d) of the vehicle code.
“(2) You will be required to return your current registration card and license plate.
“(3) You will be required to pay a restoration fee in the amount of $50 to the department in accordance with section 1960 of the vehicle code.
“(4) If you do not comply with this notice, this bureau will refer this matter to the Pennsylvania State Police for prosecution under vehicle code section 1376(A).” (emphasis added)

[46]*46Title 75 Pa.C.S. §1786(d) reads:

“Suspension of registration and operating privilege — The Department of Transportation shall suspend the registration of a vehicle if it determines the required financial responsibility [has] was not [been] secured as required by this chapter and shall suspend the operating privileges of the owner or registrant for a period of three months if the department determines that the owner or registrant has operated or permitted the operation of the vehicle without the required financial responsibility. The operating privilege will not be restored until the restoration fee for the operating privilege provided by section 1960 (relating to reinstatement of operating privileges or vehicle registration) is paid. Whenever the department revokes or suspends the registration of any vehicle under this chapter, the department shall not restore the registration until the vehicle owner furnishes proof of financial responsibility in a manner determined by the department and submits an application for registration to the department, accompanied by the fee for restoration of registration provided by section 1960.

“This subsection shall not apply in the following circumstances:

“(1) The owner or registrant proves to the satisfaction of the department that the lapse in financial responsibility coverage was for a period of less than 21 days and that the owner or registrant did not operate or permit the operation of the vehicle during the period of lapse in financial responsibility.” (emphasis added)

Section 1786(d) addresses two separate issues: driver’s licenses and vehicle registration. The Department of Transportation contends that the three-month suspension applies to driving privileges as well as vehicle registration. The appellant argues that the words [47]*47“for a period of three months” relate solely to suspension of the driver’s operating privileges, and that the language pertaining to the suspension of the vehicle’s registration does not set forth a fixed period of time that the suspension is to last. Furthermore, the appellant argues that the suspension of the owner’s registration lasts only until he or she supplies DOT with adequate proof of reinstatement of financial responsibility.

This appears to be a case of first impression. Title 75 Pa.C.S. §1786 became effective on July 1, 1990. Counsel for the parties have provided no authority interpreting the section, and our independent research has been equally unproductive.

A statute which imposes the revocation of a personal operator’s license and/or a vehicle registration combined with a fine is penal in nature. Penal statutes are to be strictly construed in favor of the accused. Commonwealth v. Darush, 256 Pa. Super. 344, 389 A.2d 1156 (1978); Commonwealth v. Cunningham, 248 Pa. Super. 219, 375 A.2d 66 (1977). If two inconsistent interpretations of statutory language are both reasonable, the benefit of doubt must inure to the defendant’s position. Commonwealth v. Teada, 235 Pa. Super.

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Related

Commonwealth v. Teada
344 A.2d 682 (Superior Court of Pennsylvania, 1975)
Commonwealth v. Darush
389 A.2d 1156 (Superior Court of Pennsylvania, 1978)
Commonwealth v. Cunningham
375 A.2d 66 (Superior Court of Pennsylvania, 1977)

Cite This Page — Counsel Stack

Bluebook (online)
14 Pa. D. & C.4th 43, 1992 Pa. Dist. & Cnty. Dec. LEXIS 341, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccrea-v-penndot-pactcomplfrankl-1992.