Freundt v. Commonwealth

In Freundt v. Commonwealth, 584 Pa. 283, 883 A.2d 503 (2005), the Court construed 1532(c) explaining that where the legislature used the separate terms "conviction" and "offense" it must have intended for the words to have different meanings. Thus, while the merger of the suspensions of operating privileges under 75 Pa. C.S. 1532(a) and 1532(a.1) is an issue of first impression for this Court, in Freundt the Court explained that, in the context of 1532(c), "when there is a conviction, the appropriate license suspension shall be determined by whether or not the conviction stemmed from a single criminal episode, or multiple criminal episodes." Freundt at 290, 883 A.2d at 507.