Freundt v. Commonwealth, Department of Transportation, Bureau of Driver Licensing, 584 Pa. 283

Summary

The Supreme Court of Pennsylvania held that 75 Pa.C.S. § 1532(c) requires a single driver's-license suspension for drug convictions arising from a single criminal episode, rather than separate suspensions for each conviction. Because the record did not establish distinct criminal episodes, the court affirmed the Commonwealth Court's order imposing one six-month suspension.

Holdings

1. For purposes of 75 Pa.C.S. § 1532(c), an offense is a single criminal episode. Multiple convictions arising from one criminal episode therefore warrant a single license suspension, while convictions arising from separate criminal episodes may warrant separate suspensions.
2. Freundt's sixteen convictions constituted a single offense because the record did not identify distinct dates for the individual counts or otherwise establish separate criminal episodes. Accordingly, only one six-month suspension was appropriate.

Questions Presented

1. Whether 75 Pa.C.S. § 1532(c) requires a separate driver's-license suspension for each conviction of a specified drug offense or a single suspension when multiple convictions arise from one criminal episode.
2. Whether the absence of distinct dates in the criminal information established that Freundt's sixteen convictions arose from a single criminal episode for purposes of § 1532(c).

Disposition

affirmed