Department of Transportation, Bureau of Driver Licensing v. Slack

In Department of Transportation, Bureau of Driver Licensing v. Slack, 153 Pa. Commw. 4, 623 A.2d 364 (Pa. Cmwlth. 1992), DOT suspended the vehicle registrations of a husband and wife (owners) under Section 1786 when their insurance company informed DOT that their insurance coverage lapsed. Id., 632 A.2d at 365. On appeal to the trial court, the owners argued that they did not receive notice that their insurance coverage had lapsed because of late payment. Id. The trial court sustained the appeal because it concluded that DOT had not met the burden of proving the owners had operated the vehicles without the required financial responsibility because there was no evidence that they intended to operate without insurance. Id. at 366. The Court reversed, agreeing with DOT's argument that "the trial court erred in incorporating an element of intent into Section 1786 which is not clearly present in the plain unambiguous language of the statute." Id. at 367.