Commonwealth v. Linton

Summary

The Supreme Court of Pennsylvania held that 75 Pa.C.S. § 3364(b)(2) requires pedalcycle operators to use reasonable efforts not to impede the normal and reasonable movement of traffic. Whether those efforts include temporarily leaving the roadway is a fact-bound question of reasonableness that must consider all relevant circumstances. The Court reversed and remanded to the Superior Court for further proceedings.

Holdings

1. Section 3364(b)(2) may, under certain circumstances, require a pedalcycle operator to leave the roadway to allow faster-moving vehicles to pass, but it does not impose an absolute duty to immediately vacate the roadway whenever faster traffic approaches.
2. Whether a pedalcycle operator violated § 3364(b)(2) requires a fact-bound assessment of reasonableness considering all relevant circumstances.
3. The Superior Court applied an incorrect legal standard by treating § 3364(b)(2) as imposing an absolute duty to use the berm and by omitting relevant evidence from its sufficiency analysis; the sufficiency issue must be reconsidered under the correct legal standard.

Questions Presented

1. Whether 75 Pa.C.S. § 3364(b)(2) requires a pedalcycle operator to leave the roadway whenever faster-moving traffic approaches or backs up.
2. What legal standard governs whether a pedalcycle operator has used reasonable efforts not to impede the normal and reasonable movement of traffic under § 3364(b)(2).

Disposition

reversed_and_remanded