Airport Officers Authority to Enforce Provisions of the Implied Consent Law Outside of Their Territorial Boundaries
In McKinley v. Department of Transportation, Bureau of Driver Licensing, 576 Pa. 85, 838 A.2d 700 (2003), our Supreme Court held that airport officers lack the authority to enforce provisions of the Implied Consent Law outside of their territorial boundaries absent an express legislative grant of extraterritorial authority.
By contrast, our General Assembly, by enacting the Municipal Police Jurisdiction Act (MPJA), has expressly authorized municipal police officers like Officer Sollenberger to enforce laws outside of their primary jurisdiction.
See also Stein v. Department of Transportation, Bureau of Driver Licensing, 857 A.2d 719 (Pa. Cmwlth. 2004) (distinguishing McKinley in case involving extraterritorial authority of municipal police officer).