Bell v. Bureau of Driver Licensing (majority)Annotate this Case
In 2011, while driving home from a funeral reception, Appellee William Bell crossed the center line of a road and struck another vehicle. A woman was killed as a result of the impact. Following trial, Bell was convicted of driving under the influence of alcohol or a controlled substance-bac.16+, homicide by vehicle while DUI, and homicide by vehicle, In this appeal, the Supreme Court addressed questions of whether convictions for homicide by vehicle and homicide by vehicle while driving under the influence (DUI) merged for operating privilege suspension purposes under the Vehicle Code, and, more generally, whether the criminal doctrine of merger was applicable to the collateral civil consequences which flow from merged, underlying criminal convictions. The Court held that the Commonwealth Court improperly found the criminal doctrine of merger was applicable in the civil arena of operating privilege suspensions under 75 Pa.C.S. sections 1532(a), (a.1). Accordingly, the Supreme Court reversed.