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Kapish v. Bureau of Driver Licensing — Ten-Year Court-Caused Delay in License Suspension Hearing Mandates Reversal Under Middaugh Due Process Test

The Commonwealth Court of Pennsylvania reversed the denial of a license suspension appeal, holding that Court Administration’s ten-year failure to schedule a hearing — despite repeated court orders to do so — constituted an extraordinary government-caused delay that violated the licensee’s due process rights under the Middaugh framework and mandated dismissal of the suspension.