§ 4524. Windshield obstructions and wipers.
(a) Obstruction on front windshield.--No person shall drive any motor vehicle with any sign, poster or other nontransparent
material upon the front windshield which materially obstructs, obscures or impairs
the driver's clear view of the highway or any intersecting highway except an inspection
certificate, sticker identification sign on a mass transit vehicle or other officially
required sticker and no person shall drive any motor vehicle with any ice or snow
on the front windshield which materially obstructs, obscures or impairs the driver's
clear view of the highway or any intersecting highway.
(b) Obstruction on side and rear windows.--No person shall drive a motor vehicle with any sign, poster or other nontransparent
material, including ice or snow, upon the side wings or side or rear windows of the
vehicle which materially obstructs, obscures or impairs the driver's clear view of
the highway or any intersecting highway. The placement of a registration permit upon
the side or rear window of a vehicle shall not be considered a material obstruction.
(c) Other obstruction.--No person shall drive any motor vehicle with any object or material hung from the
inside rearview mirror or otherwise hung, placed or attached in such a position as
to materially obstruct, obscure or impair the driver's vision through the front windshield
or any manner as to constitute a safety hazard.
(d) Windshield wiper systems.--The windshield on every motor vehicle other than a motorcycle or special mobile equipment
shall be equipped with a wiper system capable of cleaning rain, snow or other moisture
from the windshield, and so constructed as to be controlled or operated by the driver
of the vehicle.
(e) Sun screening and other materials prohibited.--
(1) No person shall drive any motor vehicle with any sun screening device or other material
which does not permit a person to see or view the inside of the vehicle through the
windshield, side wing or side window of the vehicle.
(2) This subsection does not apply to:
(i) A vehicle which is equipped with tinted windows of the type and specification that
were installed by the manufacturer of the vehicle or to any hearse, ambulance, government
vehicle or any other vehicle for which a currently valid certificate of exemption
has been issued in accordance with regulations adopted by the department.
(ii) A vehicle which is equipped with tinted windows, sun screening devices or other materials
which comply with all applicable Federal regulations and for which a currently valid
certificate of exemption for medical reasons has been issued in accordance with regulations
adopted by the department.
(3) A certificate of exemption shall be issued by the department for a vehicle which is:
(i) Registered in this Commonwealth on the effective date of this subsection and is equipped
with a sun screening device or other material prohibited under paragraph (1) on the
effective date.
(ii) Equipped with tinted windows, sun screening devices or other materials for a physical
condition that makes it necessary to equip the motor vehicle with sun screening material
which would be of a light transmittance or luminous reflectance in violation of this
section.
(A) A certificate of exemption for medical reasons shall be issued only if the owner or
registrant of the vehicle, or a person residing in the household of the owner or registrant
who regularly drives or is driven in the vehicle, suffers from a physical condition
determined by the department, in consultation with the Medical Advisory Board, to
justify the exemption.
(B) Any person requesting an exemption for medical reasons shall have his physical condition
certified to the department by a licensed physician or optometrist.
(4) A certificate of exemption issued under this subsection shall be carried in the vehicle
and displayed on request of a police officer.
(5) Upon the sale or transfer of the vehicle to any person who does not qualify under
paragraph (2)(ii), the exemption shall be null and void. Prior to the sale or transfer
of an exempt vehicle, it shall be the sole responsibility of the owner or seller of
a formerly exempt vehicle to remove all sun screening or other materials from the
vehicle. At the time of the sale or transfer of a formerly exempt vehicle, the owner
shall remove and destroy the certificate of exemption for physical reasons and provide
the purchaser with a notarized statement setting forth the name and address of the
owner or seller, the vehicle identification number, year and model, and the business
entity and process used to remove the sun screening or other material.
(f) Exception.--This section does not apply to mobile video recording equipment installed in a vehicle
exclusively used for official police purposes.
(Feb. 15, 1980, P.L.12, No.8, eff. imd.; Dec. 8, 1982, P.L.842, No.234, eff. Apr.
1, 1983; July 10, 1984, P.L.679, No.146, eff. 60 days; Nov. 21, 1990, P.L.556, No.137,
eff. 180 days; June 22, 2001, P.L.559, No.37, eff. 60 days; June 11, 2002, P.L.370,
No.53, eff. imd.)
2002 Amendment. Act 53 added subsec. (f). Section 3 of Act 53 provided that subsec. (f) shall apply
upon the enactment of a statute providing for the intercepting and recording of oral
communications under 18 Pa.C.S. § 5704. Act 52 of 2002, effective June 11, 2002, added
provisions relating to the intercepting and recording of oral communications under
18 Pa.C.S. § 5704.
2001 Amendment. Act 37 amended subsec. (b).
1990 Amendment. Act 137 amended subsec. (e).
Cross References. Section 4524 is referred to in section 8117 of Title 74 (Transportation).
Notes of Decisions
Cited in
73
cases (
22 in the last 5 years), 1988–2026 · leading case:
Commonwealth v. Rodriguez, 81 A.3d 103 (Pa. Super. Ct. 2013).
Commonwealth v. Rodriguez, 81 A.3d 103 (Pa. Super. Ct. 2013).
· cites it 11× “— (1) No person shall drive any motor vehicle with any sun screening device or other material which does not permit a person to see or view the inside of the vehicle through the windshield, side wing or side window of the vehicle.”
Commonwealth v. Holmes, 14 A.3d 89 (Pa. 2011).
· cites it 4× “Although inadequate under these circumstances to establish reasonable suspicion *100 to conduct a lawful vehicle stop, especially since the suppression court was without any means to evaluate whether the purported object materially obstructed Appellee's view, see 75 Pa.C.S. §…”
United States v. Gooch, 915 F. Supp. 2d 690 (W.D. Pa. 2012).
· cites it 12× “aking these assumptions as true, however, the Court finds that an officers ability to discern an absence of objects in the back seat of a vehicle while standing directly above of it and shining a light directly into the vehicle does not mean that the stop was unsupported by…”
Commonwealth v. Randolph, 151 A.3d 170 (Pa. Super. Ct. 2016).
· cites it 2× “See 75 Pa.C.S. § 4524(e)(1) (“no person shall drive any motor vehicle with any sun screening device or other material which does not permit a person to see or view the inside of the vehicle through the windshield, side wing or side window of the vehicle”).”
Commonwealth v. Santiago, A., Aplt., 209 A.3d 912 (Pa. 2019).
· cites it 2× “1 75 Pa.C.S. § 4524(e)(1). [J-93-2018] - 2 Immediately after Appellant fled the scene, Officer Sanchez and other officers returned to the location of the original traffic stop and retrieved a cell phone on the ground.”
Commonwealth v. Kemp, 961 A.2d 1247 (Pa. Super. Ct. 2008).
· cites it 2× “Such tinting constituted a violation of 75 Pa.C.S. § 4524(e)(1). [1] *1251 Id. at 9.”
Commonwealth v. Randal, 837 A.2d 1211 (Pa. Super. Ct. 2003).
· cites it 2× “§ 3925, and the summary offense of Windshield Obstructions and Wipers, 75 Pa.C.S. § 4524. Appellant challenges the constitutionality of what is known as Act 63 of 2000 (Act 63), Ignition Interlock Devices, codified at 42 Pa.”
Commonwealth v. By, 812 A.2d 1250 (Pa. Super. Ct. 2002).
· cites it 2× “See 75 Pa.C.S. § 4524(e). [3] We note that the trial court did not address Officer Neff's location or conduct during the interaction nor did the court discuss what effect this may have on a reasonable person's belief that he was free to leave.”
Commonwealth v. Slattery, 139 A.3d 221 (Pa. Super. Ct. 2016).
· cites it 2× “Pursuant to 75 Pa.C.S. § 4524 : (b) Obstruction on side and rear windows.”
Commonwealth v. Freeman, 150 A.3d 32 (Pa. Super. Ct. 2016).
“2008) (en banc), a state trooper monitoring traffic along the Pennsylvania Turnpike observed a vehicle with tinted windows in violation of 75 Pa.C.S. § 4524(e)(1), which gave him probable cause to initiate a valid vehicle stop.”
Commonwealth v. Anthony, 1 A.3d 914 (Pa. Super. Ct. 2010).
· cites it 5× “Anthony argues that in those cases we held that perceived violations based on the presence of objects hanging from a motorist’s rearview mirror constitute reasonable suspicion for a stop only if the officer’s observations suggest that the objects “materially obstruct, obscure or…”
Commonwealth v. Elliott, 546 A.2d 654 (Pa. 1988).
· cites it 2× “ No person shall drive a motor vehicle with any object or other material hung from the inside rearview mirror or otherwise hung, placed or attached in such a position as to materially obstruct, obscure or impair the driver's vision through the front windshield or any manner as…”
— 75 Pa. Cons. Stat. § 4524(a) — 3 cases
— 75 Pa. Cons. Stat. § 4524(b) — 3 cases
Commonwealth v. Slattery, 139 A.3d 221 (Pa. Super. Ct. 2016).
“Pursuant to 75 Pa.C.S. § 4524 : (b) Obstruction on side and rear windows.”
— 75 Pa. Cons. Stat. § 4524(c) — 13 cases
Commonwealth v. Holmes, 14 A.3d 89 (Pa. 2011).
“Although inadequate under these circumstances to establish reasonable suspicion *100 to conduct a lawful vehicle stop, especially since the suppression court was without any means to evaluate whether the purported object materially obstructed Appellee's view, see 75 Pa.C.S. §…”
Commonwealth v. Anthony, 1 A.3d 914 (Pa. Super. Ct. 2010).
“Anthony argues that in those cases we held that perceived violations based on the presence of objects hanging from a motorist’s rearview mirror constitute reasonable suspicion for a stop only if the officer’s observations suggest that the objects “materially obstruct, obscure or…”
Commonwealth v. Elliott, 546 A.2d 654 (Pa. 1988).
“ No person shall drive a motor vehicle with any object or other material hung from the inside rearview mirror or otherwise hung, placed or attached in such a position as to materially obstruct, obscure or impair the driver's vision through the front windshield or any manner as…”
— 75 Pa. Cons. Stat. § 4524(e) — 14 cases
United States v. Gooch, 915 F. Supp. 2d 690 (W.D. Pa. 2012).
“aking these assumptions as true, however, the Court finds that an officers ability to discern an absence of objects in the back seat of a vehicle while standing directly above of it and shining a light directly into the vehicle does not mean that the stop was unsupported by…”
Commonwealth v. By, 812 A.2d 1250 (Pa. Super. Ct. 2002).
“See 75 Pa.C.S. § 4524(e). [3] We note that the trial court did not address Officer Neff's location or conduct during the interaction nor did the court discuss what effect this may have on a reasonable person's belief that he was free to leave.”
Commonwealth v. Rodriguez, 81 A.3d 103 (Pa. Super. Ct. 2013).
“— (1) No person shall drive any motor vehicle with any sun screening device or other material which does not permit a person to see or view the inside of the vehicle through the windshield, side wing or side window of the vehicle.”
— 75 Pa. Cons. Stat. § 4524(e)(1) — 33 cases
Commonwealth v. Randolph, 151 A.3d 170 (Pa. Super. Ct. 2016).
“See 75 Pa.C.S. § 4524(e)(1) (“no person shall drive any motor vehicle with any sun screening device or other material which does not permit a person to see or view the inside of the vehicle through the windshield, side wing or side window of the vehicle”).”
Commonwealth v. Santiago, A., Aplt., 209 A.3d 912 (Pa. 2019).
“1 75 Pa.C.S. § 4524(e)(1). [J-93-2018] - 2 Immediately after Appellant fled the scene, Officer Sanchez and other officers returned to the location of the original traffic stop and retrieved a cell phone on the ground.”
Commonwealth v. Kemp, 961 A.2d 1247 (Pa. Super. Ct. 2008).
“Such tinting constituted a violation of 75 Pa.C.S. § 4524(e)(1). [1] *1251 Id. at 9.”
Commonwealth v. Rodriguez, 81 A.3d 103 (Pa. Super. Ct. 2013).
“— (1) No person shall drive any motor vehicle with any sun screening device or other material which does not permit a person to see or view the inside of the vehicle through the windshield, side wing or side window of the vehicle.”
Commonwealth v. Freeman, 150 A.3d 32 (Pa. Super. Ct. 2016).
“2008) (en banc), a state trooper monitoring traffic along the Pennsylvania Turnpike observed a vehicle with tinted windows in violation of 75 Pa.C.S. § 4524(e)(1), which gave him probable cause to initiate a valid vehicle stop.”
— 75 Pa. Cons. Stat. § 4524(e)(2) — 2 cases
Commonwealth v. Rodriguez, 81 A.3d 103 (Pa. Super. Ct. 2013).
“— (1) No person shall drive any motor vehicle with any sun screening device or other material which does not permit a person to see or view the inside of the vehicle through the windshield, side wing or side window of the vehicle.”
— 75 Pa. Cons. Stat. § 4524(e)(2)(i) — 1 case
Commonwealth v. Rodriguez, 81 A.3d 103 (Pa. Super. Ct. 2013).
“— (1) No person shall drive any motor vehicle with any sun screening device or other material which does not permit a person to see or view the inside of the vehicle through the windshield, side wing or side window of the vehicle.”
— 75 Pa. Cons. Stat. § 4524(e)(3) — 1 case
— 75 Pa. Cons. Stat. § 4524(e)(4) — 1 case
— 75 Pa. Cons. Stat. § 4524(e)(l) — 1 case
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