Board of Supervisors of Liberty Township v. Charnita, Inc.

34 Pa. D. & C.3d 552, 1984 Pa. Dist. & Cnty. Dec. LEXIS 229
CourtPennsylvania Court of Common Pleas, Adams County
DecidedMarch 13, 1984
Docketno. 83-S-344
StatusPublished

This text of 34 Pa. D. & C.3d 552 (Board of Supervisors of Liberty Township v. Charnita, Inc.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Adams County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Board of Supervisors of Liberty Township v. Charnita, Inc., 34 Pa. D. & C.3d 552, 1984 Pa. Dist. & Cnty. Dec. LEXIS 229 (Pa. Super. Ct. 1984).

Opinion

SPICER, P.J.,

This case involves some rather unusual facts and issues and is presented under the provisions of 20 Pa. C.S. §8301 et seq. As everyone knows, those provisions are the reenacted versions of the Revised Price Act and are part of the Probate, Estates and Fiduciaries Code, 20 Pa. C.S. § 101 et seq. Chapter 83 of that code empowers common pleas courts to authorize the sale, mortgage, lease, or exchange of real property held by corporations with no capacity to convey or where legal title is otherwise inalienable.

Petitioner is the Board of Supervisors of Liberty Township and the case involves real estate situated within that township. The petition alleges the following facts.

Persons named Morgan conveyed a tract of land to a corporation called Charnita, Inc. on December 17, 1969. An 85.21 acre portion of this tract was designated by Charnita as section AD on a subdivision plan.

Charnita obtained another tract from persons named Weishaar on December 31, 1969. A 63 acre portion of this tract was designated by Charnita as section AE on its subdivision plan.

This subdivision plan was submitted to plaintiff and was approved. The complaint does not allege but it is undoubtedly true that a number of lots were sold by Charnita after this approval.

[554]*554A citizens group appealed the approval to this court. On March 15, 1974, an order was entered by the Honorable Clinton R. Weidner, specially presiding, reversing approval and directing that “no land development shall be made, including streets, sanitary sewers, storm sewers, water mains, or other improvements in connection therewith, except in accordance with . . . subdivision regulations.”

The order plainly stated that the township’s approval was reversed but said nothing about either past or future conveyances.

Some time after the order, Charnita filed for bankruptcy. Although no formal order of discharge has ever been entered, the corporation has ceased to function and to exist, except in perhaps a technical sense.

Several lot owners filed answers to the petition. Others filed preliminary objections. Those objections raised two challenges to the township’s action. The owners claimed the township had no interest in the case and no capacity to sue. Also contended was that the land held by individual lot owners is not inalienable. The owners concede they cannot build upon or develop their properties because of the court order, but could sell and convey.

It became apparent that the test of inalienabiltiy would involve the effect of the township’s subdivision ordinance. If conveyances by Charnita were void because violative of the regulations, there would be no individual lots, only a large tract still owned by a defunct corporation. If the conveyances were not void, future sales of those lots cannot be said to be a subdivision since that occurred when Charnita conveyed.

Generally, contracts, the performance of which violate a law, are void and unenforceable. 17 Am Jur 2d contracts §165, Dippel v. Brunozzi, 365 Pa. 264, [555]*55574 A.2d 112 (1950). Even so, a part of that rule is:

“Where a contract is found to be against public policy “it cannot, under any circumstances, be made the basis of a cause of action. The law when appealed to will have nothing to do with it, but will leave the parties just in the condition in which it finds them. If they have, fully executed their unlawful contract, the law will not disturb them in possession of what each has acquired under it.” Id. at 267, 74 A.2d at 114.

Pennsylvania courts have enforced contracts involving collateral on relatively insignificant illegalities. Contractor Industries v. Zerr, 241 Pa. Super. 92, 359 A.2d 803 (1976). See also, O’Brien v. O’Brien Steel Construction Co., 440 Pa. 375, 271 A.2d 254 (1970); Shafer v. A.I.T.S., Inc., 285 Pa. Super. 490, 428 A.2d 152 (1981).

These cases and the general law in the area concern disputes between the parties to a contract. The present case involves something entirely different and, perhaps, much more serious. The issue, narrowly framed, is whether a municipality can, in the absence of allegations that the public welfare is affected, void a completed contract which apparently conformed to subdivision regulations at performance but which actually violated those regulations.

The issue of standing and entitlement to relief are closely associated in this case.

There is no doubt that subdivision regulations relate directly to public welfare. 53 P.S. §10105. The Township has a genuine concern in this area and a right to see that its regulations are enforced. Commonwealth v. Fisher, 23 Pa. Commw. 25, 350 A.2d 428, cert. denied 429 U.S. 1026, 50 L.Ed.2d 629, 97 S. Ct. 649 (1976). There would seem to be little doubt that the township would ordinarily have [556]*556standing when enforcement of its regulations are involved. Shohola Township Board of Supervisors v. Bishop, 279 Pa. Super. 313, 421 A.2d 215 (1980).

There appears to be a split in authority concerning whether violations of subdivison regulations, without more, voids a transfer of real estate. See Failure of Vendor to Comply with Statute or Ordinance Requiring Approval or Recording of Plat Prior to Conveyance of Property as rendering Sale Void or Voidable, 77 A.L.R.3d 1058 (1977). Some of the cases in other jurisdictions which appear to hold that conveyances in violation of such regulations are void actually deal with unperformed contracts and don’t necessarily hold conveyances to be void. For example, it was said in Smith v. Bach, 183 Cal. 259, 191 P. 14 (1920) that conveyances violating land regulations concerning recordation of a map, were void. However, in commenting on the California Rule, a federal court stated:

“Where contracts for the sale of real estate in California or Hawaii are not in compliance with respective laws, the contracts are regarded as void or voidable ...” In re Los Angeles Land and Investments, Ltd., 282 F. Supp. 448, 451 (D. Hawaii 1968) aff’d 447 F.2d 1366 (9th Cir. 1971).

A reading of the collected cases in 77 A.L.R.3d, supra, beginning on page 1060, could lead one to conclude that grantees in the “void” jurisdiction can declare the conveyances void. None of these cases involve municipalities as parties and the holdings probably could more accurately be described as classifying the conveyances as voidable.

Other jurisdictions hold conveyances in violation of restrictions not to be void. These decisions seem to involve statutory construction of the particular statute or law. In Montagna v. Marston, 24 Md. App. 354, 330 A.2d 502 (1975) the Maryland Court [557]*557viewed statutory authorization to enjoin conveyances as a legislative determination that such conveyances were not void.

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Related

Marriott Financial Services, Inc. v. Capitol Funds, Inc.
217 S.E.2d 551 (Supreme Court of North Carolina, 1975)
DIPPEL v. Brunozzi
74 A.2d 112 (Supreme Court of Pennsylvania, 1950)
In Re Los Angeles Land and Investments, Ltd.
282 F. Supp. 448 (D. Hawaii, 1968)
Contractor Industries v. Zerr
359 A.2d 803 (Superior Court of Pennsylvania, 1976)
Shohola Township Board of Supervisors v. Bishop
421 A.2d 215 (Superior Court of Pennsylvania, 1980)
Shafer v. A. I. T. S., Inc.
428 A.2d 152 (Superior Court of Pennsylvania, 1981)
Commonwealth v. Fisher
350 A.2d 428 (Commonwealth Court of Pennsylvania, 1976)
Montagna v. Marston
330 A.2d 502 (Court of Special Appeals of Maryland, 1975)
Smith v. Bach
191 P. 14 (California Supreme Court, 1920)
O'Brien v. O'Brien Steel Construction Co.
271 A.2d 254 (Supreme Court of Pennsylvania, 1970)

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Bluebook (online)
34 Pa. D. & C.3d 552, 1984 Pa. Dist. & Cnty. Dec. LEXIS 229, Counsel Stack Legal Research, https://law.counselstack.com/opinion/board-of-supervisors-of-liberty-township-v-charnita-inc-pactcompladams-1984.