Sweet Stevens’ Barbetta Successfully Argues PA Supreme Court Case
New Britain, PA – Justin D. Barbetta of Sweet, Stevens, Katz & Williams LLP, recently won a case before the Supreme Court of Pennsylvania relating to multiple parties who took parallel challenges to a single property’s partial tax exemption. Barbetta successfully argued that the legal doctrines being applied in the dismissal of the firm’s client’s appeal did not apply to this case, thus providing an opportunity for their tax appeal to be heard on its own merits.
In 2013, Huston Properties, the owner of a historically significant property in Coatesville, Chester County, Pennsylvania, sought tax exempt status for the property, saying it was being used as “an institution of purely public charity.” In response, the Chester County Board of Assessment Appeals granted a partial tax exemption of 72% and reduced the property’s assessment form $954,450 to $267,250.
The City of Coatesville appealed to the Chester County Court of Common Pleas, the court that hears tax assessment appeals, challenging the partially tax-exempt status. Six days later, the Coatesville Area School District, a client of Sweet Stevens, lodged its own challenge. When a trial was held and the judge affirmed the exemption status, he issued two identical but separate but orders for each appeal.
Both the city and the school district appealed to the Commonwealth Court of Pennsylvania, as did the taxpayer. The intermediate court consolidated the four appeals and, in their decision, vacated the decision, remanding the case back to the lower court for more specific findings to support the tax exemption. The trial court responded with new findings, reaffirming its earlier decision.
While the city then elected not to appeal to the commonwealth court, the school district did. In dismissing the district’s appeal, the court observed that because the school district had intervened in the city’s matter, it was a party to those proceedings, citing two legal doctrines: res judicata, literally, “a thing adjudicated,” which bars actions on a claim, or any part of a claim, which was the subject of a prior action, and collateral estoppel, a similar doctrine, which bars re-litigation of an issue that was decided in a prior action.
The district appealed to the Pennsylvania Supreme Court, who found that a straightforward application of those doctrines were “complicated by multiple factors,” the most significant of which in that the city and the school district were not acting as one party, rather, parallel ones, albeit in a single action in terms of the issue. In short, they found that, because the city opted not to appeal in the matter does not mean that the school district could not, saying that the lower court’s decision “did not serve to shield [the property owner] or the courts from repetitive or abuse litigation, but to thwart the School District’s substantive appellate rights.”
“This was a very unique set of facts and procedural history,” said Barbetta after the decision. “We appreciate the careful consideration of the justices in ensuring that the rights of the school district were upheld.”
Click here to read the full opinion.
Sweet, Stevens, Katz & Williams, LLP was formed in 1995 by nine experienced education lawyers who created the first private law practice in Pennsylvania dedicated entirely to Education Law. Since then, the firm has grown to 24 attorneys who represent over 290 school and municipal entities as Solicitors or as Special Counsel in more than 50 counties throughout Pennsylvania.