The Commonwealth Court of Pennsylvania has overturned the suspension of Rockland Collision Center, Inc.’s official safety inspection license, ruling that the Department of Transportation (PennDOT) failed to follow proper legal procedures in its notification and lacked sufficient evidence for some of the alleged violations.
The decision, issued by Judge Stacy Wallace, stems from a lengthy dispute initiated by PennDOT’s suspension of Rockland Collision Center’s Certificate of Appointment as an Official Safety Inspection Station. The initial suspension was verbally issued on May 12, 2022, and formalized in a notice sent on June 1, 2022.
Procedural Flaws Sink PennDOT’s Case
The core of the appellate court’s ruling hinged on a critical procedural error: PennDOT’s failure to properly notify the Inspection Station of the specific laws it was accused of breaking.
Rockland Collision Center argued that PennDOT violated its due process rights because the notice only cited Section 4724 of the Vehicle Code (which grants PennDOT the authority to suspend licenses) and the penalty provision, 67 Pa. Code § 175.51(a). It did not cite the *substantive* regulations or Code sections that defined the alleged offenses.
The Commonwealth Court agreed, pointing to its own precedent in *Manna v. Dep’t of Transp.* In that case, the court found that due process requires citation to the specific statutory or regulatory provisions that were allegedly violated. The trial court had mistakenly believed that citing the penalty provision, § 175.51(a), was sufficient, but the appellate court clarified that a penalty provision merely lists potential punishments; it doesn’t define the prohibited conduct.
Because the notice forced the Inspection Station to “speculate as to what provisions [it] violated,” the court concluded that PennDOT’s failure to cite substantive provisions violated the Inspection Station’s due process rights, necessitating a reversal.
Evidence Gaps for Specific Allegations
Beyond the notice issue, the appellate court found that PennDOT failed to meet its burden of proof regarding two specific categories of violations, which were allegedly tied to the May 12, 2022, audit date. PennDOT must prove its allegations by a preponderance of the evidence.
The violations concerning furnishing or selling inspection certificates without inspection, and failing to provide customers with written receipts or work orders, were found unsupported by substantial evidence for the specified date. PennDOT’s own auditors testified they were unsure if the station was even performing inspections on May 12, 2022. While PennDOT used the missing tools on that date to *infer* that improper inspections occurred, the court found this inferential leap insufficient to prove those specific offenses occurred on that day.
However, the court found the date of May 12, 2022, appropriate for allegations related to missing tools and improper recordkeeping, as those deficiencies were directly observed during the audit.
Omissions Are Not Necessarily Fraud
The third major issue addressed was whether the extensive recordkeeping failures amounted to “fraudulent recordkeeping.” PennDOT’s auditors detailed severe deficiencies: hundreds of inspections missing from the official MV-431 log, missing tire and brake measurements, and the use of impossible measurements (all tires being 9/16ths of an inch).
The court defined fraudulent recordkeeping as an entry that is “false, entered intentionally and with the purpose of deceiving.” While the evidence strongly suggested negligence—with employees admitting they were too busy or didn’t receive the data—it did not prove intent to deceive.
The court noted that while the inspector’s claim that all tires measured 9/16ths was “deceitful,” that specific measurement was not actually recorded in the official MV-431 log. The recorded omissions, while “grossly inadequate,” were not proven to have been made with the purpose of misleading an inspector into believing the records were correct. Therefore, the trial court erred as a matter of law by equating gross omissions with fraud.
Conclusion
Despite expressing “grave concerns” about how Rockland Collision Center was conducting its business, the Commonwealth Court determined that PennDOT’s administrative process was flawed from the start. The court reversed the trial court’s order that had reinstated the suspension, effectively clearing the Inspection Station of the administrative penalty imposed by PennDOT.