Gingrich factors (Pennsylvania) · Go Syfert
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Gingrich factors in Pennsylvania

12 Pennsylvania opinions name it 2 courts 2016–2021 1 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 (5)

CaseFollowedCited
S. Middaugh v. PennDOT, Bureau of Driver Licensinggreen
pacommwct · 2018 · cited in 6 Pennsylvania opinions naming this issue, 2018–2019
2 sentences

2019For example, this Court has affirmed decisions of the courts of common pleas which held that non-Departmental delays of 9 years, 7 years and 10 months, 2 years and 7 months, and 2 years and 4 months can be considered extraordinarily extended periods of time to meet Gingrich’s first factor, where the other Gingrich factors were also satisfied.[] Middaugh, 196 A.3d at 1083 (internal footnote omitted).

2019For example, this Court has affirmed decisions of the courts of common pleas which held that non-Departmental delays of 9 years, 7 years and 10 months, 2 years and 7 months, and 2 years and 4 months can be considered extraordinarily extended periods of time to meet Gingrich’s first factor, where the other Gingrich factors were also satisfied.[] Middaugh, 196 A.3d at 1083 (internal footnote omitted).

46
R.T. Currie v. PennDOT, Bureau of Driver Licensinggreen
pacommwct · 2016 · cited in 3 Pennsylvania opinions naming this issue, 2017–2018
2 sentences

2017The Gingrich factors were also recently balanced in Currie v. Department of Transportation, Bureau of Driver Licensing, 142 A.3d 186, 187 (Pa. Cmwlth. 2016), where the delay caused by a non-Penn-DOT entity was nearly three years.

2017The Gingrich factors were also recently balanced in Currie v. Department of Transportation, Bureau of Driver Licensing, 142 A.3d 186, 187 (Pa. Cmwlth. 2016), where the delay caused by a non-Penn-DOT entity was nearly three years.

33
Capizzi v. PennDOT, Bureau of Driver Licensinggreen
pacommwct · 2016 · cited in 4 Pennsylvania opinions naming this issue, 2016–2017
2 sentences

2017That said, however, we have concluded that there may be limited extraordinary circumstances where the suspension loses its public protection rationale and simply becomes an additional punitive measure resulting from the conviction, but imposed long after the fact. 134 A.3d at 534 . 7 Accord Orwig v. Department of Transportation, Bureau of Driver Licensing, (Pa. Cmwlth., No. 286 C.D. 2015, filed June 3, 2016) (unreported) (applying the Gingrich exception where ten years elapsed between the conviction and the clerk of court’s reporting of the conviction to the Department); see Eckenrode v. Depar

2017That said, however, we have concluded that there may be limited extraordinary circumstances where the suspension loses its public protection rationale and simply becomes an additional punitive measure resulting from the conviction, but imposed long after the fact. 134 A.3d at 534 . 7 Accord Orwig v. Department of Transportation, Bureau of Driver Licensing, (Pa. Cmwlth., No. 286 C.D. 2015, filed June 3, 2016) (unreported) (applying the Gingrich exception where ten years elapsed between the conviction and the clerk of court’s reporting of the conviction to the Department); see Eckenrode v. Depar

24
Gingrich v. Commonwealth, Department of Transportation, Bureau of Driver Licensinggreen
pacommwct · 2016 · cited in 4 Pennsylvania opinions naming this issue, 2017–2021
2 sentences

2021It was added to the Gingrich test by the panel in the present matter to serve “the need for consistency and certainty in Gingrich’s application,” id. at 1086 n.17, and to balance objectives relating to public safety with drivers’ due process rights.

2021It was added to the Gingrich test by the panel in the present matter to serve “the need for consistency and certainty in Gingrich’s application,” id. at 1086 n.17, and to balance objectives relating to public safety with drivers’ due process rights.

14
Bingnear v. Workers' Compensation Appeal Boardgreen
pacommwct · 2008 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016Appeal Bd. (City of Chester), 960 A.2d 890, 896 (Pa. Cmwlth. 2008); see also Sch.

2016Appeal Bd. (City of Chester), 960 A.2d 890, 896 (Pa. Cmwlth. 2008); see also Sch.

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 (5)

CaseCitedYears
Gifford v. Commonwealth, Department of Transportation, Bureau of Driver Licensing green
pacommwct · 2017
2 sentences

2019As explained by the Court in DeGrossi v. Department of Transportation, Bureau of Driver Licensing , 174 A.3d 1187 (Pa. Cmwlth. 2017), a statement in an unreported opinion of this Court that Pokoy "remains good law" may have led to some confusion as to the applicability of Pokoy in light of Gingrich . 4 The Court in DeGrossi went on to discuss our decision in Gifford v. Department of Transportation, Bureau of Driver Licensing , 172 A.3d 727 (Pa. Cmwlth. 2017), appeal dismissed as moot , --- Pa. ----, 201 A.3d 734 (2019), wherein we applied Gingrich and held that a clerk of court's delay in info

2019As explained by the Court in DeGrossi v. Department of Transportation, Bureau of Driver Licensing , 174 A.3d 1187 (Pa. Cmwlth. 2017), a statement in an unreported opinion of this Court that Pokoy "remains good law" may have led to some confusion as to the applicability of Pokoy in light of Gingrich . 4 The Court in DeGrossi went on to discuss our decision in Gifford v. Department of Transportation, Bureau of Driver Licensing , 172 A.3d 727 (Pa. Cmwlth. 2017), appeal dismissed as moot , --- Pa. ----, 201 A.3d 734 (2019), wherein we applied Gingrich and held that a clerk of court's delay in info

22019–2019
Commonwealth v. Gifford neutral
pa · 2019
2 sentences

2019As explained by the Court in DeGrossi v. Department of Transportation, Bureau of Driver Licensing , 174 A.3d 1187 (Pa. Cmwlth. 2017), a statement in an unreported opinion of this Court that Pokoy "remains good law" may have led to some confusion as to the applicability of Pokoy in light of Gingrich . 4 The Court in DeGrossi went on to discuss our decision in Gifford v. Department of Transportation, Bureau of Driver Licensing , 172 A.3d 727 (Pa. Cmwlth. 2017), appeal dismissed as moot , --- Pa. ----, 201 A.3d 734 (2019), wherein we applied Gingrich and held that a clerk of court's delay in info

2019As explained by the Court in DeGrossi v. Department of Transportation, Bureau of Driver Licensing , 174 A.3d 1187 (Pa. Cmwlth. 2017), a statement in an unreported opinion of this Court that Pokoy "remains good law" may have led to some confusion as to the applicability of Pokoy in light of Gingrich . 4 The Court in DeGrossi went on to discuss our decision in Gifford v. Department of Transportation, Bureau of Driver Licensing , 172 A.3d 727 (Pa. Cmwlth. 2017), appeal dismissed as moot , --- Pa. ----, 201 A.3d 734 (2019), wherein we applied Gingrich and held that a clerk of court's delay in info

22019–2019
Negovan v. Commonwealth, Department of Transportation, Bureau of Driver Licensing green
pacommwct · 2017
2 sentences

2019On appeal to this Court, the Department argued that the trial court 4 “Our standard of review in a license suspension case is to determine whether the factual findings of the trial court are supported by competent evidence and whether the trial court committed an error of law or an abuse of discretion.” Negovan v. Department of Transportation, Bureau of Driver Licensing, 172 A.3d 733 , 735 n.4 (Pa. Cmwlth. 2017) (quoting Gammer v. Department of Transportation, Bureau of Driver Licensing, 995 A.2d 380 , 383 n.3 (Pa. Cmwlth. 2010)). 5 erred because Gingrich required a delay of approximately 10 y

2019On appeal to this Court, the Department argued that the trial court 4 “Our standard of review in a license suspension case is to determine whether the factual findings of the trial court are supported by competent evidence and whether the trial court committed an error of law or an abuse of discretion.” Negovan v. Department of Transportation, Bureau of Driver Licensing, 172 A.3d 733 , 735 n.4 (Pa. Cmwlth. 2017) (quoting Gammer v. Department of Transportation, Bureau of Driver Licensing, 995 A.2d 380 , 383 n.3 (Pa. Cmwlth. 2010)). 5 erred because Gingrich required a delay of approximately 10 y

12019–2019
Gammer v. Commonwealth, Department of Transportation, Bureau of Driver Licensing green
pacommwct · 2010
2 sentences

2019On appeal to this Court, the Department argued that the trial court 4 “Our standard of review in a license suspension case is to determine whether the factual findings of the trial court are supported by competent evidence and whether the trial court committed an error of law or an abuse of discretion.” Negovan v. Department of Transportation, Bureau of Driver Licensing, 172 A.3d 733 , 735 n.4 (Pa. Cmwlth. 2017) (quoting Gammer v. Department of Transportation, Bureau of Driver Licensing, 995 A.2d 380 , 383 n.3 (Pa. Cmwlth. 2010)). 5 erred because Gingrich required a delay of approximately 10 y

2019On appeal to this Court, the Department argued that the trial court 4 “Our standard of review in a license suspension case is to determine whether the factual findings of the trial court are supported by competent evidence and whether the trial court committed an error of law or an abuse of discretion.” Negovan v. Department of Transportation, Bureau of Driver Licensing, 172 A.3d 733 , 735 n.4 (Pa. Cmwlth. 2017) (quoting Gammer v. Department of Transportation, Bureau of Driver Licensing, 995 A.2d 380 , 383 n.3 (Pa. Cmwlth. 2010)). 5 erred because Gingrich required a delay of approximately 10 y

12019–2019
Pokoy v. Commonwealth, Department of Transportation, Bureau of Driver Licensing green
pacommwct · 1998
2 sentences

2017However, in Pokoy v. Department of Transportation, Bureau of Driver Licensing, 714 A.2d 1162 (Pa. Cmwlth. 1998), this Court concluded that a four-year delay, again attributable to the clerk of courts, was insufficient to set aside the license suspension.

2017However, in Pokoy v. Department of Transportation, Bureau of Driver Licensing, 714 A.2d 1162 (Pa. Cmwlth. 1998), this Court concluded that a four-year delay, again attributable to the clerk of courts, was insufficient to set aside the license suspension.

12017–2017

Statutes the citing opinions construe

PA § 75 Pa. Cons. Stat. § 6323 (10) PA § 75 Pa. Cons. Stat. § 1532 (8) PA § 75 Pa. Cons. Stat. § 3804 (5) PA § 75 Pa. Cons. Stat. § 3802 (4) PA § 75 Pa. Cons. Stat. § 101 (3) PA § 75 Pa. Cons. Stat. § 1581 (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 12 (2016–2021) IL 2 (2005–2005)

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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