Brown v. Com., State Bd. of Pharmacy

DOYLE, Judge,

concurring and dissenting.

I agree with the majority opinion insofar as it concludes that one possesses a property right in a suspended license. I dissent, however, from that portion of the opinion which concludes that there has been an impermissible retroactive application of the pertinent statute to Petitioner’s case.

The Board held that Petitioner could not apply for reinstatement until ten years after his conviction date. It based its determination on the ten-year limitation appearing in Section 5(d) of the Pharmacy Act,1 63 P.S. § 390-5(d), which Section, as noted by the majority, did not become effective until January 1,1986. Petitioner maintains that the application of the ten-year provision to him would constitute an impermissible retroactive application. The Board contends, on the other hand, that since the amendment to the Pharmacy Act became effective on January 1, 1986 and Petitioner applied for reinstatement on October 4,1988, the mandatory *650ten-year suspension provision has not been retrospectively applied to him.

We have already determined, in a case where the licensee was convicted and his license automatically suspended after January 1, 1986, that “[u]nder the Pharmacy Act, the event which results in the automatic suspension of Petitioner’s license ... is his “conviction” of felonies under the Drug Act.” Morris v. Department of State, Bureau of Professional and Occupational Affairs, State Board of Pharmacy, 113 Pa.Commonwealth Ct. 318, 322, 537 A.2d 93, 95 (1988). Here, Petitioner was convicted of felonies under the Drug Act prior to the effective date of Section 5(d) of the Pharmacy Act; therefore, there is no question that the automatic suspension provision appearing in Section 5.1 of the Pharmacy Act, formerly 63 P.S. § 390-5a, (later repealed and reenacted as Section 7(d.2), 63 P.S. § 390-7(d.2)) was applicable to Petitioner’s case. Under the Pharmacy Act, prior to the enactment of the ten-year limitation in Section 5(d), a pharmacist who had his or her license suspended possessed a right to petition for a hearing for reinstatement at any time. The question of when such petition would be granted was not specifically covered by statute. Petitioner concedes that under the prior law, because the Act did not set any specific time limit for reinstatement from suspension, that issue was determined by the Board in the exercise of its discretion.2

The inquiry, thus, is once a licensee’s license has been suspended (whether automatically or otherwise) does an act of the legislature barring an application for reinstatement for ten years apply to those licenses already suspended, or does the Act apply only to licensees’ whose licenses are suspended after the effective date of the new law? I *651believe the former is the correct analysis and the better view based on the underlying legal principles.

It is well-settled principle of law that when a statutory amendment involves a procedural change, rather than a revision of substantive rights, there is no constitutional objection to retrospective application. Lang v. County of Delaware, 88 Pa.Commonwealth Ct. 452, 490 A.2d 20 (1985); Crisante v. J.H. Beers, Inc., 297 Pa. Superior Ct. 337, 443 A.2d 1150 (1982). As Judge Palladino wrote in Bortulin v. Harley-Davidson Motor Co., Inc., 115 Pa.Commonwealth Ct. 42, 539 A.2d 906 (1988),

In determining whether a particular statute is to be given retroactive effect, the Pennsylvania Supreme Court has distinguished between statutes which impact upon procedural matters and those which affect a party’s substantive rights. In Bell v. Koppers Co., Inc., the Supreme Court concluded that when a party’s substantive rights are involved, the law which was in effect at the time the cause of action arose must be applied. In contrast, procedural rules are applicable to actions instituted after the effective date of the rules ... [where the date of the occurrence which gave rise to the action occurred prior to the effective date of the rule].

Id., 115 Pa.Commonwealth Ct. at 47, 539 A.2d at 909 (emphasis in original).

It is clear that Section 5(d) was intended to relate only to the period of time a pharmacist who has been convicted of drug felonies must wait before applying for reinstatement. There is no infringement upon the pharmacist’s right to a hearing subsequent to his conviction and suspension, only a ten-year limitation before that right may be realized. Further, Section 5(d) does not change basic rights since prior to the enactment of Section 5(d), the Board, in its discretion, could allow a hearing at any time (even after only one week) or require the licensee to wait twenty years. Section 5(d) simply substitutes for the Board’s discretionary powers a legislatively mandated ten-year delay. I am convinced such was a proper legislative function and should apply to all suspended licenses, including those previously suspended.

*652I note that in Crisante the Superior Court held that a statute of limitations which had been reduced by amendment could be applied retroactively because it was procedural and not substantive. The instant case presents the mirror image of Crisante as we are not here applying a statute to limit the end date of the amount of time a party may have to institute an action, but rather, simply applying a statute delaying the starting date of Petitioner’s right to petition for a reinstatement hearing. Since it is constitutionally permissible to allow retroactive application of a statute which cuts off an individual’s right to bring a suit because such statute is procedural, retroactive application of Section 5(d) to this case where rights are not cut off, but merely delayed, must also be permitted.

Accordingly, I would affirm the Board’s order denying the petition for a reinstatement hearing until October 23, 1995.

. Act of September 27, 1961, P.L., 1700, as amended.

. Petitioner stresses that the suspension procedures are penal in nature and must be strictly construed; however, we are addressing the reinstatement procedures, not the suspension procedures. These are regulatory in nature, i.e., they regulate those persons who practice pharmacology in the Commonwealth. See Galena v. Department of State, 122 Pa.Commonwealth Ct. 315, 551 A.2d 676 (1988).