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Bob Mayberry Chevrolet, Inc. v. Commonwealth

Citations: 55 Pa. Commw. 186; 422 A.2d 1222; 1980 Pa. Commw. LEXIS 1904Docket: Appeal, No. 2455 C.D. 1979

Court: Commonwealth Court of Pennsylvania; December 7, 1980; Pennsylvania; State Appellate Court

Narrative Opinion Summary

This case involves an appeal from an order of the Court of Common Pleas of Mercer County, affirming the Pennsylvania Department of Transportation's decision to suspend the appellant's Certificate of Appointment as an official inspection station for three months. The suspension was predicated on an alleged faulty inspection conducted by an employee of the appellant, in violation of Section 4724(a) of the Vehicle Code. The appellant contested the suspension, raising multiple issues, including due process violations concerning the notice of violation and the imposition of strict liability without the employer's knowledge of the employee's actions. After a thorough examination, President Judge Stranahan found no due process infringement, upheld the application of strict liability, and confirmed that substantial evidence supported the violation finding. Consequently, the appellate court affirmed the lower court's decision on December 8, 1980, maintaining the suspension imposed by the Pennsylvania Department of Transportation.

Legal Issues Addressed

Due Process and Notice of Violation

Application: The court determined that the notice of violation and suspension provided to the appellant did not infringe upon constitutional due process rights.

Reasoning: The notice of violation and suspension did not infringe upon the appellant's due process rights.

Strict Liability in Employer-Employee Violations

Application: The court upheld the suspension based on the actions of the appellant's employee, ruling that imposing strict liability on the employer without their knowledge of the employee's actions was not a due process violation.

Reasoning: The suspension for a violation related to an employee's actions, without the employer’s knowledge, did not violate due process by imposing strict liability.

Substantial Evidence Requirement

Application: The court found that substantial evidence supported the finding of a violation of Section 4724(a) of the Vehicle Code by the appellant.

Reasoning: Substantial evidence was presented to demonstrate a violation of Section 4724(a) of the Vehicle Code.