McKinley v. Commonwealth of Pennsylvania, Department of Transportation, Bureau of Driver Licensing, 564 Pa. 565

Summary

The Pennsylvania Supreme Court considered whether a Harrisburg International Airport police corporal qualified as a "police officer" under the Motor Vehicle Code's Implied Consent Law. The court held that the Aviation Code authorized the corporal to make arrests for violations of law, but that the authority was limited to airport premises. Because the effect of the officer's extraterritorial conduct on the license suspension was unresolved, the court vacated the Commonwealth Court's order and remanded for further proceedings.

Holdings

1. A duly commissioned HIA corporal is a police officer for purposes of Section 1547 of the Vehicle Code because the Aviation Code and incorporated provisions authorized the corporal to make arrests for violations of law.
2. The HIA corporal's arrest authority was limited to airport grounds; the applicable statutes did not expressly confer extraterritorial authority.
3. The Supreme Court did not decide the ultimate effect of the extraterritorial encounter. It remanded to the Commonwealth Court to determine whether the encounter affected the officer's status under the Implied Consent Law, the reasonable-grounds requirement, or the availability of suppression in the civil proceeding.

Questions Presented

1. Whether a duly commissioned Harrisburg International Airport police corporal qualifies as a police officer for purposes of Pennsylvania's Implied Consent Law.
2. Whether the Aviation Code and related statutory provisions limited the HIA corporal's arrest authority to airport property.
3. What consequence, if any, the officer's extraterritorial stop and arrest has in a civil administrative license-suspension proceeding under the Implied Consent Law.

Disposition

vacated