vehicle while violation (Pennsylvania) · Go Syfert
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vehicle while violation in Pennsylvania

21 Pennsylvania opinions name it 1 courts 2007–2025 5 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Martinovic v. Commonwealth, Department of Transportation, Bureau of Driver Licensinggreen
pacommwct · 2005 · cited in 12 Pennsylvania opinions naming this issue, 2007–2025
2 sentences

2025Section 1547(b) of the Vehicle Code provides: “[i]f any person placed under arrest for a violation of section 3802 is requested to submit to chemical testing and refuses to do so,” the Department shall suspend the operating privilege for 1 year, or 18 months under certain conditions. 75 Pa.C.S. §1547(b). 5 Martinovic v. Dep’t of Transp., Bureau of Driver Licensing, 881 A.2d 30, 34 (Pa. Cmwlth. 2005).4 This Court reviews the question of whether and officer had reasonable grounds on a case-by-case basis.

2024Garlick, 176 A.3d at 1035 (citing Martinovic v. Dep’t of Transp., Bureau of Driver Licensing, 881 A.2d 30, 34 (Pa. Cmwlth. 2005)).

1212
Piasecki v. Commonwealth, Department of Transportation, Bureau of Driver Licensinggreen
pacommwct · 2010 · cited in 3 Pennsylvania opinions naming this issue, 2019–2019
2 sentences

2019Piasecki v. Department of Transportation, Bureau of Driver Licensing, 6 A.3d 1067, 1070 (Pa. Cmwlth. 2010). 5 test; (3) Licensee refused to do so; and (4) Licensee was specifically warned that a refusal would result in the suspension of his operating privileges and would result in enhanced penalties if he was later convicted of violating Section 3802(a)(1).

2019Piasecki v. Department of Transportation, Bureau of Driver Licensing, 6 A.3d 1067, 1070 (Pa. Cmwlth. 2010). 5 Martinovic v. Department of Transportation, Bureau of Driver Licensing, 881 A.2d 30, 34 (Pa. Cmwlth. 2005).

33
Garlick v. Commonwealth, Department of Transportation, Bureau of Driver Licensinggreen
pacommwct · 2018 · cited in 3 Pennsylvania opinions naming this issue, 2023–2024
2 sentences

2024Garlick, 176 A.3d at 1035 (citing Martinovic v. Dep’t of Transp., Bureau of Driver Licensing, 881 A.2d 30, 34 (Pa. Cmwlth. 2005)).

2024Garlick v. Dep’t of Transp., Bureau of Driver Licensing, 176 A.3d 1030, 1035 (Pa. Cmwlth. 2018). 2 law student I am somebody who knows you must read a case at least like five times before you can even understand what’s in it,’ before the officer forcibly removed the form from [Licensee.]” Id. at 3.

23
Quick v. Commonwealth, Department of Transportation, Bureau of Driver Licensinggreen
pacommwct · 2007 · cited in 2 Pennsylvania opinions naming this issue, 2008–2009
2 sentences

2009Quick v. Dept. of Transp., Bureau of Driver Licensing, 915 A.2d 1268, 1271 (Pa.Cmwlth.2007).

2008Quick v. Department of Transportation, Bureau of Driver Licensing, 915 A.2d 1268, 1270 (Pa.Cmwlth.2007).

22
Nardone v. Commonwealth, Department of Transportation, Bureau of Driver Licensinggreen
pa · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019In order to support a suspension of Licensee’s operating privilege under section 1547(b)(1) of the Vehicle Code, DOT had the burden of proving the following: (1) Licensee was arrested for violating Section 3802 of the Vehicle Code by a police officer who had “reasonable grounds to believe” that [l]icensee was operating or was in actual physical control of the movement of a vehicle while in violation of Section 3802 (i.e., while driving under the influence); (2) Licensee was asked to submit to a chemical test; (3) Licensee refused to do so; and (4) Licensee was specifically warned that a refusa

11
Negovan v. Commonwealth, Department of Transportation, Bureau of Driver Licensinggreen
pacommwct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
1 sentence

2018Martinovic v. Dep’t of Transp., Bureau of Driver Licensing, 881 A.2d '30, 34 (Pa. Cmwlth. 2005) (emphasis ádded).' There is no constitutional requirement for a police officer to provide any warning to a licensee of the consequences of his failure to submit to a blood test, Negovan v. Department of Transportation, Bureau of Driver Licensing, 172 A.3d 733, 737 (Pa. Cmwlth. 2017); however, there is a statutory requirement, 75 Pa. C.S. § T547(b)(2)(ii).

11
Birchfield v. N. Dakota. William Robert Bernardgreen
scotus · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
1 sentence

2018See id.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Reinhart v. Commonwealth, Department of Transportation, Bureau of Driver Licensing green
pacommwct · 2008
1 sentence

2018Reinhart v. Dep’t of Transp., Bureau of Driver Licensing, 954 A.2d 761 , 765 n.3 (Pa. Cmwlth. 2008). 4 operating privileges and would result in enhanced penalties if he was later convicted of violating Section 3802(a)(1).

12018–2018
Reinhart v. Commonwealth, Department of Transportation green
pacommwct · 2008
1 sentence

2017Reinhart v. Dep’t of Transp., Bureau of Driver Licensing, 946 A.2d 167 (Pa. Cmwlth. 2008). 4 (1) Licensee was arrested for violating Section 3802 of the Vehicle Code by a police officer who had ‘reasonable grounds to believe’ that Licensee was operating or was in actual physical control of the movement of the vehicle while in violation of Section 3802 (i.e., while [DUI]); (2) Licensee was asked to submit to a chemical test; (3) Licensee refused to do so; and[,] (4) Licensee was specifically warned that a refusal would result in the suspension of his operating privileges.

12017–2017

Statutes the citing opinions construe

PA § 75 Pa. Cons. Stat. § 1547 (21) PA § 75 Pa. Cons. Stat. § 3802 (16) PA § 75 Pa. Cons. Stat. § 3804 (4) PA § 75 Pa. Cons. Stat. § 1550 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 21 (2007–2025) WA 2 (1998–1998)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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