Bell v. Commonwealth, Department of Transportation, Bureau of Driver Licensing

OPINION

Justice STEVENS.

In this appeal, we address the questions of whether convictions for homicide by vehicle and homicide by vehicle while driving under the influence (DUI) merge for operating privilege suspension purposes under the Vehicle Code,1 and, more generally, whether the criminal doctrine of merger is applicable to the collateral civil consequences which flow from merged, underlying criminal convictions. For the reasons that follow, we hold that the Commonwealth Court improperly found the criminal doctrine of merger is applicable in the civil arena of operating privilege…