Duffey v. Dept. of Transp.

The principle that a licensee may not collaterally attack an underlying criminal conviction in civil license suspension proceedings has been firmly established. To conclude, as the Majority does, that this principle is inapplicable to the factual scenario presented in the case sub judice misapprehends that appeals from a license suspension are civil in nature. Department of Transportation, Bureau of Traffic Safety v. Calloway, 60 Pa.Commonwealth Ct. 647, 432 A.2d 322 (1981). Moreover, accepting as legally accurate the premise that the license suspension imposed against Duffey represented the…