## Facts

- Felix Olshefski owned a truck used to haul coal.
- Under Pennsylvania’s Vehicle Code, the truck’s maximum allowable gross weight was 15,750 pounds.
- While Olshefski was out of town, his driver, John Fisher, took the truck to the Gilberton Coal Company to be loaded with coal.
- After loading, the coal company provided Fisher a weigh slip showing the truck’s gross weight as 15,200 pounds, which was under the statutory limit.
- Fisher drove the loaded truck to Olshefski’s home and left the weigh slip in the truck.
- The next day, Olshefski went to a bank in Danville and saw police officers checking the weights of trucks at the north end of a river bridge.
- Olshefski returned home and, shortly afterward, drove the loaded coal truck back toward Danville.
- Olshefski was headed to Danville’s scales to obtain a Danville weigh slip because a city ordinance required a Danville weigh slip to sell coal in the city.
- Before Olshefski reached the Danville scales, a police officer directed him to a different set of scales used for enforcement.
- The enforcement weighing produced a weigh slip showing a gross weight of 16,015 pounds—265 pounds over the legal limit.
- Olshefski was cited for violating the Vehicle Code’s weight restriction, and the matter was brought to court for disposition.
- Olshefski contended he acted in good faith based on the earlier 15,200-pound weigh slip and lacked knowledge that the truck was overweight.

## Issues

1. Whether the Vehicle Code’s overweight-truck offense requires the Commonwealth to prove the defendant knew the vehicle exceeded the statutory gross-weight limit.
2. Whether an operator’s good-faith reliance on an earlier, facially valid weigh slip (and an honest mistake about the truck’s weight) is a defense when the truck is overweight at the time of operation.

## Decision

- The court upheld the overweight-vehicle conviction.
- The court treated the statutory weight-limit violation as a public-welfare offense for which proof of intent or knowledge was not required.
- The Commonwealth’s burden was satisfied by showing that the defendant operated the truck on the highway when it in fact exceeded the statutory weight limit.
- The defendant’s reliance on the earlier coal-company weigh slip and his claimed lack of awareness did not excuse the violation.

## Legal Principles

- Vehicle weight-limit provisions aimed at protecting highways and public safety may be enforced as public-welfare offenses.
- For a public-welfare strict-liability offense, the Commonwealth need not prove a culpable mental state if the statute does not make knowledge or intent an element.
- A mistake of fact about weight, including good-faith reliance on a prior private weigh slip, does not bar conviction absent a statutory exception.
- The relevant inquiry is the vehicle’s gross weight at the time it is operated on the highway; if the truck is overweight then, the offense is complete.

## Conclusion

Commonwealth v. Olshefski holds that operating an overweight truck in violation of Pennsylvania’s Vehicle Code is a strict-liability public-welfare offense: once the Commonwealth proves the truck was overweight when driven, the defendant cannot avoid liability by showing good-faith reliance on an earlier weigh slip or lack of knowledge of the overage.


Commonwealth v. Olshefski, 64 Pa. D. & C. 343 (1948)