Commonwealth v. Strunk

POPOVICH, Judge,

dissenting opinion:

I dissent. Upon thorough review of the record and statutory provisions herein relevant, I disagree, first, with the majority's characterization of the test of “rational relationship” under the substantive component of the Due Process Clause. Second, armed with the improper test, the majority thereupon undertook a misguided analysis and in so doing creates dangerous, if not boundless, precedent.

The thrust of the majority opinion can be found in the conclusion that the test for “rational relation” as derived from the substantive implications of the Due Process Clause compels that the penalty (here, suspension of driver’s privileges), need be related to the crime (here, the crime of underage drinking), only so far as the legislature might have rationally believed that it serves a “deterrent func*40tion.” Hence, the majority considers the constitutional test fully satisfied if the penalty, however arbitrarily arrived at, is rationally related to achieving any state interest.

Under a substantive due process analysis regarding the constitutionality of section 6310.4 [mandated termination of driver’s licence for conviction under § 6308], we are not concerned with whether 6310.4 is rationally related to section 6308 [violation for person under 21 years old to, inter alia, possess brewed beverages].
a rational relationship need only exist between the state interest(s) (deterrence and punishment) and the challenged legislation (section 6310.4).

Ante 582 A.2d at 1328-29 & n. 6.

I find this suggestion unpersuasive, as both incomplete on the law and dangerous as a matter of precedent. Yet, in no way do I seek to denigrate the sense of public urgency and social concern associated with underage drinking. Thus, I find it well within the bounds of rationality that the legislature considered removal of a driver’s license as “deterring” youthful drinking. The majority, however, cites not one United States Supreme Court, Pennsylvania Supreme Court or Pennsylvania Superior Court decision in support of this singular “deterrence” approach to judicial scrutiny under the Due Process Clause.1 Contrarily, I find judicial inquiry properly framed under the Due Process Clause as demanding that we consider the rationality, or irrationality, of suspending operator’s privileges where a *41minor is convicted of underage drinking and where a motor vehicle is not implicated.

Perhaps the dearth of case precedent in support of the majority’s position bespeaks the inherent weakness of the doctrine and the subsumed illogic thereof. The test of judicial scrutiny under the substantive component of the due process clause is not a unidirectional or unidimensional one looking exclusively at the state end—here, preventing underage drinking—and simply asking whether the statute at issue serves a deterrent function with respect to the crime. I suggest the test of rationality is not so narrowly confined, and that there must also be a “rational relationship” or nexus between the end and the means so as not to make selection of the particular means entirely arbitrary as a matter of penology.

There exists within our penal system a rationality such that a fine or penalty should reflect the gravity or moral reproachability of a particular crime. One might wonder, and rightly so, why the legislature singled out underage drinking as deserving of a truly “special” penalty, whereas other offenses committed by juveniles such as vandalism, shoplifting, disorderly conduct, loitering, etc., receive a much different penalty. Indeed, if the focus is on the intractable nature of juvenile deterrence, then removal of one’s license might serve the much-needed deterrent function with respect to each of these crimes, yet there appears no rational reason to afford one crime, but not the other, separate treatment. Perhaps most troublesome is that when selection of a penalty is arbitrary, the public, as well as the individual offender, is more prone to perceive the penal system as arbitrary in punishing for offenses not committed. Moreover, the offense of driving while intoxicated already commands a significant penalty which presumably serves a considerable deterrent function. Thus, without an indication that the crime of underage drinking was accompanied by the operation of a motor vehicle, the mere fact that drinking is associated with driving in the abstract will not suffice to supply the requisite rationality.

*42The two Pennsylvania Commonwealth Court cases relied on by the majority in defense of the “deterrent” interest are, at least, inapposite; at most, they argue against rather than for the majority position. In both cases the means utilized by the state (suspension of driver’s license), was rationally related to a violation of the motor vehicle code. In Lemon, supra, the defendant was convicted of 75 Pa.C. S.A. § 211(a) for possession of a forged inspection certificate; in Deems, supra, the defendant was convicted of 75 Pa.C.S.A. § 304 for the sale of a vehicle with defaced numbers. Thus, while the state might have had a deterrence interest in preventing such activity, the suspension of a driver’s license was entirely reasonable since the crimes involved the unlawful operation or sale of a motor vehicle.

Instantly, while the majority found a “deterrent” interest supported by the penalty of license suspension, I am hard-pressed to fathom a penalty which, assuming the appropriate severity, does not serve a similar function. With this as the standard, I see no standard at all. Moreover, our task, contrary to the majority’s interpretation, is not to ignore the express relationship offered by the legislature and immediately hypothesize as to possible rational relationships. A plain interpretation of the statute confirms a relationship as between the offense of underage possession of brewed beverages and the penalty of, inter alia, suspension of operator’s privileges.2 Our task must be to ascertain whether the relationship was reached in an arbitrary manner. To be sure, ignoring the rationality of the relationship might be to further to some degree a serious problem with juvenile crime. But without a coherent limiting principle, the doctrine announced by the majority today has much *43graver implications beyond the facts at bar. I fear that the majority, by offering its imprimatur, sanctions judicial tolerance of arbitrary forms of penology and thereby paves the way for analogous laws.3 The potential of breeding public distrust and lack of confidence in the soundness of law enforcement is manifest. As a result, I cannot join the majority opinion and would hold 18 Pa.C.S.A. § 6310.4 an arbitrary legislative enactment since violation may occur irrespective of the operation of a motor vehicle, and yet the statutory penalty includes suspension of operator’s privileges.

. Analogous laws have met with mixed responses in the state courts. Compare People v. Lindner, 127 I11.2d 174, 535 N.E.2d 829 (1989) (irrational and arbitrary for state to punish crimes of sexual assault, where an automobile was not implicated, with suspension of operator’s privileges) and 4 Op. Idaho Att'y Gen. 1, 5 (1984) (concluding that “[l]oss of a driver’s license for violation of a law unrelated to driving amounts to an arbitrary forfeiture of a state created property interest without justification.”) with Matter of Maricopa County, 160 Ariz. 90, 770 P.2d 394 (1989) (announcing that Arizona legislature considered suspension of driver’s license to serve as a deterrent of underage drinking is sufficient under due process inquiry) and with State v. Smith, 58 N.J. 202, 276 A.2d 369 (1971) (law requiring suspension of driver’s license for narcotics conviction rationally related to state interest in highway safety and deterrence of narcotics usage).

. Appellant pleaded guilty to charges under section 6308(a) of underage purchase, consumption, possession or transportation of brewed beverages. Section 6308(b), the penalty provision, provides:

In addition to the penalty imposed pursuant to section 6310.4 (relating to restriction of operating privileges), a person convicted of violating section (a) ... [may be sentenced to pay a fine]. Section 6310.4 provides:
Whenever a person is convicted [of section] ... 6308 ... the court ... shall order the operating privilege of the person suspended.

. The test of “rational relationship” as defined by the “deterrence” rationale is not logically cabined solely to the offense of underage drinking or offenses committed by minors. Consider a legislature desirous of deterring juvenile vandalism. Under today’s rationale, and owing to the intractable nature of juvenile deterrence, the legislature might rationally consider suspension of operator’s privileges as an effective deterrent. Following like reasoning, the legislature might penalize public drunkenness or disorderly conduct or loitering with suspension of operator’s privileges. To be sure, these are but a few examples. Troublesome with the "deterrence” rationale is that its limits are largely defined by the ingenuity of legislators, not by the test of rationale relationship under the substantive component to the Due Process Clause.