In Linkosky v. Commonwealth of PA, Dept. of Transp., Bur. of Driver Licensing, the Pennsylvania Supreme Court addressed whether the Department of Transportation erred by denying a licensee’s application for a duplicate camera card. When the licensee sought to replace the card, which he lost, his operating privileges had been suspended in Ohio. The Commonwealth Court held that the licensee’s request for a duplicate camera card should not have triggered an inquiry in the National Driver Registry (“NDR”) because his request did not seek a grant or extension of driving privileges or the issuance of a license that the licensee did not already possess. The Supreme Court reversed and held that, because the licensee requested a duplicate temporary license in the form of a duplicate camera card, the Department had a duty to inquire with the Register before issuing the license. Thus, the Department did not err by denying the license.
