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Zalewski v. Commonwealth

The suspension of a Pennsylvania driver's license, based on a New Jersey DUI conviction, was upheld where the information conveyed by the New Jersey authorities was sufficient to allow the driver to prepare an effective defense.

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Submitted: December 22, 2000

Joseph Zalewski (Licensee) appeals from an order of the Court of Common Pleas of Bucks County (trial court), denying his appeal and directing the Department of Transportation, Bureau of Driver Licensing (DOT) to reinstate the one-year suspension of his operating privilege imposed by DOT pursuant to Section 1532(b)(3) and Article IV(a)(2) of Section 1581 of the Vehicle Code (Code), 75 Pa. C.S. ��1532(b)(3), 1581. *fn1 We affirm.

The underlying facts of this case are not in dispute. On December 18, 1999, Licensee was arrested in Plainsboro Township, Middlesex County, New Jersey and charged with violating N.J.S. �39:4-50 (relating to driving under the influence of liquor or drugs). *fn2 On February 2, 2000, Licensee appeared in the Plainsboro Township Municipal Court and entered a plea of guilty to this charge with a “civil reservation.” *fn3 The Municipal Court in New Jersey thereafter convicted Licensee and entered his plea with this “civil reservation.” *fn4 As both New Jersey and Pennsylvania are members of the Compact, authorities in New Jersey reported the conviction to authorities in Pennsylvania, as required by Article III of the Compact. *fn5

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