S. Zaidi v. Bureau of Motor Vehicles

CourtCommonwealth Court of Pennsylvania
DecidedJune 5, 2025
Docket996-1001 C.D. 2023
StatusUnpublished

This text of S. Zaidi v. Bureau of Motor Vehicles (S. Zaidi v. Bureau of Motor Vehicles) 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
S. Zaidi v. Bureau of Motor Vehicles, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Syed Zaidi, : Appellant : : v. : No. 996 C.D. 2023 : No. 998 C.D. 2023 Commonwealth of Pennsylvania, : ARGUED: September 9, 2024 Department of Transportation, : Bureau of Motor Vehicles :

Grady Walker, III, : Appellant : : v. : No. 997 C.D. 2023 : No. 999 C.D. 2023 Commonwealth of Pennsylvania, : Department of Transportation, : Bureau of Motor Vehicles :

BJM Automotive, LLC, : Appellant : : v. : No. 1000 C.D. 2023 : No. 1001 C.D. 2023 Commonwealth of Pennsylvania, : Department of Transportation, : Bureau of Motor Vehicles :

BEFORE: HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE BONNIE BRIGANCE LEADBETTER, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY SENIOR JUDGE LEADBETTER FILED: June 5, 2025 BJM Automotive, LLC, Syed Zaidi, and Grady Walker, III (collectively, Appellants) appeal from the order of the Court of Common Pleas of Dauphin County denying their respective appeals of the Department of Transportation, Bureau of Motor Vehicles’ (the Department) suspension of their privileges to conduct motor vehicle safety and emission inspections1 and other penalties imposed. We affirm in part and reverse in part. The penalties resulted from an audit conducted by a Quality Assurance Officer2 (QAO) employed by Parsons, a private company that conducts audits of inspection stations for the Department. The audit was initiated when the QAO was given a spreadsheet which contained emission inspection information from the Department about 33 vehicles inspected by BJM from March 1 to March 21, 2021. The QAO investigated BJM’s emission and safety records for these vehicles and found problems with the information entered into emission records for four of the vehicles, a 2000 Ford F-150 Truck, a 2012 Chevrolet Malibu, a 2012 Dodge, and a 2016 Ford, the former two inspected by Zaidi and the latter two inspected by Walker. As a result of the investigation, the Department issued letters suspending BJM’s certificate of appointment as a safety inspection station and certificate of appointment as an emission inspection station; and Walker and Zaidi’s certifications as official safety inspectors and certifications as official emission inspectors (for each Appellant, referred to herein as safety inspection privileges and emission inspection privileges). With respect to their safety inspection privileges, Appellants were each suspended one year for fraudulent recordkeeping and two

1 Appellants are all represented by the same counsel. The six captioned appeals concern the Department’s action against each Appellant’s safety inspection privilege and emission inspection privilege. The matters were consolidated by this Court.

2 The trial court cites the QAO’s testimony extensively and implicitly found it credible. 2 months for improperly assigning a certificate of inspection. The suspension terms were to run consecutively for total suspensions of one year and two months for each Appellant. With respect to their emission inspection privileges, Appellants were each disciplined for faulty inspection of equipment or parts, fraudulent recordkeeping, and improperly assigning certificate of inspection. The Department imposed different sanctions upon Appellants based upon the different schedules of penalties for emission inspection stations, 67 Pa. Code § 177.602, and emission inspectors, 67 Pa. Code § 177.603. The Department issued the following sanctions to BJM: for faulty inspection of equipment and parts, a three-month suspension and $1,000 fine; for fraudulent recordkeeping, a one-year suspension and $2,500 fine; and for improperly assigning certificate of inspection, a one-month suspension. The Department issued the following sanctions to Zaidi and Walker: for faulty inspection of equipment and parts, a three-month suspension; for fraudulent recordkeeping, a one-year suspension; and for improperly assigning certificate of inspection, a warning. The suspension terms for each of Appellants’ offenses were to run consecutively with each other, for total suspensions of one year and four months for BJM and one year and three months for Zaidi and Walker. Appellants appealed the Department’s disciplinary actions to the trial court. The trial court held a single hearing on all these matters and an unrelated set of safety privilege suspensions resulting from alleged violations by Appellants Walker and BJM involving the inspection of a 2007 GMC Canyon in October 2021.3 The QAO, Zaidi, and Walker each testified at the hearing. The trial court issued an

3 Although the cases were not consolidated, the trial court issued a single order disposing of both the instant cases and the appeals involving the 2007 GMC Canyon. BJM’s appeal in the 2007 GMC Canyon case was sustained and Walker’s was denied by the trial court.

3 order denying the appeals with respect to the cases currently at issue and granting the appeals of BJM and Zaidi (but not Walker) with respect to the 2007 GMC Canyon matters. In the 2007 GMC Canyon matters, the appeals of BJM and Zaidi were not granted until after they had served the full suspension term of 14 months. The instant appeal to this Court followed.4 In its narrative recitation of the facts, the trial court found as follows. BJM is an official safety inspection station and official emission inspection station for the Department, and Zaidi is an official emission inspector employed by BJM.5 Walker, an official safety inspector and official emission inspector, although not employed by BJM, uses its equipment and safety and emission inspection certificates when dealing with his own customers. The QAO’s testimony, which the trial court implicitly adopted as fact, was that under the procedures used in Pennsylvania’s emission testing program, vehicles registered in certain counties of the Commonwealth are required to undergo emission testing. Of those counties for which emission testing is required, “visual” emission testing is required for vehicles registered in some counties, including Luzerne and Lycoming, and on-board diagnostic (OBD) emission testing is required for vehicles registered in others, including Dauphin.6 (Trial Ct. Op. at 5.) Visual

4 The trial court granted supersedeas in the instant appeals until resolution by this Court.

5 Although suspended as a safety inspector, Zaidi testified that he is not one.

6 This and the remainder of the QAO’s testimony regarding requirements for emission testing represent a less technical and simplified description of the Department’s emission inspection regulations. The Department’s emission inspection regulations define “I/M region” (I/M refers to “Inspection/Maintenance”), to mean “[t]he designation and grouping of counties in the Commonwealth certified under [67 Pa. Code] § 177.51(d) (relating to program requirements for purposes of administration of emission inspection requirements).” 67 Pa. Code § 177.3. Currently, of the counties at issue, Dauphin is in the South Central Region and Luzerne and Lycoming are in the Northern Region. 33 Pa.B. 4864 (Sept. 27, 2003). In the South Central Region, vehicles 1996 and newer with a gross vehicle weight rating of 8,500 pounds and under are subject to, inter alia, (Footnote continued on next page…) 4 testing requires an inspector to check the gas cap of a vehicle (if a gas cap is used on the vehicle in question) for leaks and to visually check to ensure that the vehicle is equipped with certain components and that those components function. OBD testing requires an inspector to plug an electronic analyzer called an “OBD module” into the vehicle’s on-board data link connector. (Id.) An OBD test is more sophisticated and accurate than a visual emission test, and more frequently triggers failing emission tests because it is more sensitive in detecting problems than a visual test.

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S. Zaidi v. Bureau of Motor Vehicles, Counsel Stack Legal Research, https://law.counselstack.com/opinion/s-zaidi-v-bureau-of-motor-vehicles-pacommwct-2025.