G. Kuzni v. PA PUC

CourtCommonwealth Court of Pennsylvania
DecidedApril 17, 2026
Docket1592 C.D. 2024
StatusUnpublished
AuthorWojcik

This text of G. Kuzni v. PA PUC (G. Kuzni v. PA PUC) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
G. Kuzni v. PA PUC, (Pa. Ct. App. 2026).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

George Kuzni, : : Petitioner : : v. : No. 1592 C.D. 2024 : Submitted: March 3, 2026 Pennsylvania Public : Utility Commission, : : Respondent :

BEFORE: HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE MATTHEW S. WOLF, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE WOJCIK FILED: April 17, 2026

George Kuzni (Petitioner), appearing pro se, petitions for review from an October 3, 2024 letter from the Pennsylvania Public Utility Commission (PUC) rejecting his “Motion to Reconsider/Notice to Cease and Desist” (motion for reconsideration). Also before this Court for disposition is the PUC’s application for relief in the form of a motion to dismiss appeal (motion to dismiss), which this Court shall treat as an application for summary relief pursuant to Pennsylvania Rule of Appellate Procedure 1532(b), Pa.R.A.P. 1532(b). For the reasons that follow, we grant the motion to dismiss. On September 11, 2024, Petitioner filed a formal complaint with the PUC related to service provided by the Stillwater Lakes Civic Association/Stillwater Sewer Corporation (Stillwater Entities). Attachment A to the PUC’s Motion to Dismiss. The formal complaint indicated it was filed based on this Court’s ruling in the case of Stillwater Lakes Civic Association, Inc. v. Kuzni (Pa. Cmwlth., No. 998 C.D. 2018, filed February 5, 2020) (Kuzni I). On September 18, 2024, the PUC issued a letter to Petitioner indicating that it no longer regulated the Stillwater Entities.1 On September 30, 2024, Petitioner filed his motion for reconsideration.2 By letter dated October 3, 2024, the PUC rejected Petitioner’s motion for reconsideration, reiterating that “the [PUC] no longer has jurisdiction or authority over Stillwater Sewer Corporation nor Stillwater Lakes Water Corporation. Both certificates of convenience allowing the companies to operate as regulated utilities were cancelled.” Exhibit C to the PUC’s Motion to Dismiss. Petitioner filed a “notice of appeal” on October 21, 2024, which this Court treated as a pro se communication indicating his intent to appeal from the decision of the PUC. Thereafter, on November 26, 2024, Petitioner filed his ancillary petition for review. Both filings assert that based on this Court’s holding in Kuzni I, the PUC continues to have jurisdiction over the Stillwater Entities.

1 The letter stated in part:

Still[w]ater’s [sic] regulation by the [PUC] was challenged in 2010. The Commonwealth Court ruled that Still[w]ater was a cooperative association and did not need authority from the [PUC] to operate its facilities. Therefore, the [PUC] is barred from hearing complaints about Still[w]ater, and we are returning your complaint.

Attachment B to the PUC’s Motion to Dismiss.

2 The motion for reconsideration asked that the PUC “immediately enter an order revoking the classification of [the Stillwater Entities] as; [sic] ‘Bona fide Co-operative Associations.’” Petitioner’s Motion for Reconsideration, Attached to Petitioner’s Notice of Appeal. 2 The PUC’s Motion to Dismiss Pa.R.A.P. 1532 provides in pertinent part:

(b) Summary relief.—At any time after the filing of a petition for review in an appellate or original jurisdiction matter, the court may on application enter judgment if the right of the applicant thereto is clear.

***

Paragraph (b) authorizes immediate disposition of a petition for review, similar to the type of relief envisioned by the Pennsylvania Rules of Civil Procedure regarding judgment on the pleadings and peremptory and summary judgment. However, such relief may be requested before the pleadings are closed where the right of the applicant is clear. Here the PUC asserts that, contrary to Petitioner’s claims, this Court has determined that the Stillwater Entities are not public utilities subject to the Commission’s jurisdiction. Indeed, in Collazo v. Pennsylvania Public Utility Commission (Pa. Cmwlth., No. 725 C.D. 2010, filed October 21, 2010) (Collazo I) and Collazo v. Pennsylvania Public Utility Commission (Pa. Cmwlth., No. 145 C.D. 2023, filed July 25, 2023) (Collazo II), this Court held that Stillwater Entities are not public entities as defined by the Public Utility Code (Code)3 and are not under the jurisdiction of the PUC. The PUC argues that the instant matter raises the same legal question that was raised and rejected in Collazo I and Collazo II—whether the Stillwater Entities are subject to the PUC’s jurisdiction. As such, under the doctrine of res judicata, there is no need to relitigate this issue and the PUC asks that we dismiss the instant action.4

3 66 Pa. C.S. §§101-3316. 4 Petitioner’s response focuses on the merits of his claim and reiterates his belief that the holding in Kuzni I reflects that the PUC has jurisdiction over the Stillwater Entities. 3 “Res judicata encompasses two related, but distinct principles: technical res judicata and collateral estoppel.” J.S. v. Department of Human Services, 221 A.3d 333, 341 (Pa. Cmwlth. 2019) (quoting C.J. v. Department of Public Welfare, 960 A.2d 494, 499 (Pa. Cmwlth. 2008)). Res judicata, or claim preclusion, bars a claim where there has been a final judgment on the merits of that claim, or issue, in a prior action. In re Coatesville Area School District, 244 A.3d 373, 378 (Pa. 2021). It bars any claims actually litigated as well as those that should have been litigated in the prior action. Id. For res judicata to apply, there must be identity of (1) the issues, (2) the causes of action, (3) the persons and parties to the action, and (4) the quality or capacity of the parties suing or being sued. Id. Generally, causes of action are identical when the subject matter and the ultimate issues are the same in both the old and new proceedings. Id. In the same way, the doctrine of collateral estoppel bars a subsequent lawsuit where (1) an issue decided in a prior action is identical to one presented in a later action; (2) the prior action resulted in a final judgment on the merits; (3) the party against whom collateral estoppel is asserted was a party to the prior action, or is in privity with a party to the prior action; and (4) the party against whom collateral estoppel is asserted had a full and fair opportunity to litigate the issue in the prior action. In re Coatesville Area School District, 244 A.3d at 378. Occasionally, “the courts add a fifth element, namely, that resolution of the issue in the prior proceeding was essential to the judgment.” Id. Both doctrines are “judicially-created precept[s]” based on practical considerations including avoiding the “‘cost and vexation’ of repetitive litigation, conserving judicial resources, ‘and, by preventing inconsistent decisions, [and] encourag[ing] reliance on adjudication.’” In re Coatesville Area School District,

4 244 A.3d at 379, 380 (quoting Office of Disciplinary Counsel v. Kiesewetter, 889 A.2d 47, 50-51 (Pa. 2005)). In Collazo I, the pro se petitioner filed a complaint with the PUC alleging, inter alia, that the Stillwater Sewer Corporation, a wholly owned subsidiary of the Stillwater Lakes Civic Association, was a de facto public utility under the jurisdiction of the PUC and that it was providing illegal public utility service without a certificate of public convenience from the PUC. The PUC ultimately rejected this argument. On appeal, this Court affirmed, agreeing with the PUC that the Stillwater Lakes Civic Association met all of the requirements of a bona fide cooperative association and was therefore exempt from the PUC’s jurisdiction pursuant to Section 102 of the Code, 66 Pa. C.S. §102. The Collazo I Court stated:

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Related

C.J. v. Department of Public Welfare
960 A.2d 494 (Commonwealth Court of Pennsylvania, 2008)
Office of Disciplinary Counsel v. Kiesewetter
889 A.2d 47 (Supreme Court of Pennsylvania, 2005)
Philadelphia Ass'n of Wholesale Opticians v. Public Utility Commission
30 A.2d 712 (Superior Court of Pennsylvania, 1942)

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Bluebook (online)
G. Kuzni v. PA PUC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/g-kuzni-v-pa-puc-pacommwct-2026.