Montchal v. Department of Transportation, Bureau of Driver Licensing

In Montchal v. Department of Transportation, Bureau of Driver Licensing, 794 A.2d 973 (Pa. Cmwlth. 2002), an 80-year-old licensee crashed into a tree. The police also received a complaint from a neighbor about her driving. The police recommended she be reexamined. The licensee failed the driving, traffic signs and laws sections of the examination. DOT then recalled her license. The trial court sustained the licensee's appeal on the basis DOT could not recall the license solely on the police recommendation without a medical report. In reversing, we determined DOT could recall the license based on the licensee's failure to pass the driving test and that medical reports were unnecessary.