In re: Condemnation of Property in Rem ~ Appeal of: J.L. Clemens & K.B. Clemens

CourtCommonwealth Court of Pennsylvania
DecidedFebruary 4, 2025
Docket1101 & 1198 C.D. 2023
StatusPublished

This text of In re: Condemnation of Property in Rem ~ Appeal of: J.L. Clemens & K.B. Clemens (In re: Condemnation of Property in Rem ~ Appeal of: J.L. Clemens & K.B. Clemens) 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
In re: Condemnation of Property in Rem ~ Appeal of: J.L. Clemens & K.B. Clemens, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

In re: Condemnation of Property in : CASES CONSOLIDATED Rem Identified as Tax Parcel : Number 62-00-02014-00-3 in the : Township of Upper Salford : Montgomery County, Pennsylvania : : Township of Upper Salford : Condemnor and Jeffrey L. Clemens : and Kelly B. Clemens : : Appeal of: Jeffrey L. Clemens and : Kelly B. Clemens : No. 1101 C.D. 2023 : In re: Condemnation of Property in : Rem Identified as Tax Parcel : Number 62-00-02014-00-3 in the : Township of Upper Salford : Montgomery County, Pennsylvania : : Township of Upper Salford : Condemnor and Jeffrey L. Clemens : and Kelly B. Clemens : : Appeal of: Barry Yeager and : No. 1198 C.D. 2023 Wyn Yeager : Argued: December 9, 2024

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge (P.) HONORABLE MARY HANNAH LEAVITT, Senior Judge

OPINION BY SENIOR JUDGE LEAVITT FILED: February 4, 2025

Before this Court are the consolidated appeals filed by Jeffrey L. Clemens and Kelly B. Clemens (Landowners) and Barry Yeager and Wyn Yeager (Intervenors) to challenge an order of the Court of Common Pleas of Montgomery County (trial court) that overruled their preliminary objections to the declaration of taking filed by the Township of Upper Salford (Township). On appeal, Landowners and Intervenors argue that the trial court erred in finding that the real and fundamental purpose of the Township’s taking was for a recreational purpose and, as such, authorized by Section 2201 of The Second Class Township Code (Township Code).1 They contend that the record evidence demonstrated that the true purpose of the Township’s taking was to preserve open space, and Section 8 of what is commonly referred to as the Open Space Lands Act (Lands Act)2 authorizes only a county to condemn land for the purpose of preserving open space. Upon review, we affirm. Background At issue is a 22.34-acre parcel of land identified as Lot 1 on Spring Mount Road, Tax Parcel No. 62-00-02014-00-3 (Property) in the Township. On March 25, 2021, Landowners entered into a sales agreement with Intervenors for the transfer of the Property, with closing scheduled for July 22, 2022. On July 20, 2022, the Township filed a declaration of taking to acquire “a fee simple title” to the Property for purposes of provid[ing] open space, parks, active and passive recreational opportunities for the residents of [the] Township, and preservation of a unique and valuable natural resource and natural area within [the] Township, in furtherance with the Township’s Open Space Plan.

Landowners Reproduced Record at 29a (R.R. __) (emphasis added). The declaration of taking recited the condemnation was authorized by the Township Code and the condemnation resolution (Resolution 2022-9) passed by the Township Board of Supervisors (Township Supervisors) on July 12, 2022.

1 Act of May 1, 1933, P.L. 103, as amended, 53 P.S. §67201. 2 Act of January 19, 1968, P.L. (1967) 992, as amended, 32 P.S. §5008. 2 Resolution 2022-9 stated, likewise, that the taking of the Property was “for open space, parks, active and passive recreational activities for the residents of [the] Township, and preservation of unique and valuable natural resource and natural area within the Township[.]” R.R. 22a. It identified the Property as being adjacent to or within an area of importance and significance for preservation and conservation as part of the Spring Mountain Conservation Landscape in the Natural Areas Inventory Update adopted and published by Montgomery County [County] in 2008, and within the Spring Mountain Woods area designated as the highest priority site in the 1995 Natural Resources Areas Inventory by [the] County[.]

Id. The resolution stated that the Property is “constrained and significantly limited in its suitability for development for residential and residential accessory uses” due to its physical features such as “significant steep slopes.” Id. 23a. Landowners and Intervenors filed preliminary objections to the declaration of taking, asserting that the Lands Act prohibited the Township from condemning the Property for the purpose of preserving open space. They claimed that before the Township could condemn land for a recreational purpose, it was required to have previously adopted a concrete recreation plan. The Township lacked such a plan. The preliminary objections also challenged the statement in Resolution 2022-9 that the Property was not suitable for residential development. This statement was belied by the 2008 filing of a preliminary plan to develop 12 residential lots on the Property. Attached to the preliminary objections was a copy of an email sent on March 24, 2021, from Theodore Poatsy, a Township supervisor, to Landowners, stating that the Township was interested in acquiring the Property, which “will be open forever and the groundwater recharge and aquifers will remain undisturbed.”

3 R.R. 19a. In that email, Poatsy proposed to name the parcel “the Clemens Open Space Property or Clemens Woods Property as part of [the Township’s] park/trail system.” Id. The parties conducted discovery. The documents and depositions produced in discovery became the evidentiary record on which the trial court decided the preliminary objections. Intervenors submitted into the record the Township’s 2007 Open Space and Recreation Plan, which identified the Property as part of “an important greenway connector” to link the Perkiomen Trail to the Township Park. R.R. 183a. The term “greenway” was defined as a “linear open space established along a natural corridor . . . [to] connect parks, preserved areas, cultural resources, or historic sites[.]” Id. 167a. In his deposition, Township Supervisor Poatsy testified that he and Kevin O’Donnell, chairman of the Township Supervisors at the time, walked through the Property in 2020, with Landowners’ permission. This walk persuaded Poatsy that “it was a nice property adjacent to our park, the Perkiomen Trail we were completing[,] and it would make [] a beautiful addition to our park township trails system.” Poatsy Dep. at 16; R.R. 354a. The Township then began applying for grants “to preserve this property because of the canopy, because of the trees, because of the streams, because of the [] beautiful area.” Poatsy Dep. at 18; R.R. 355a. Poatsy testified that the Township had adopted a recreation plan that proposed placing a trail on the Property to connect the Township’s trail system. In 1995, the Township designated the Property for a trail when it “planned the entire township for potential trail connections;” however, the Township did not approach Landowners until 2020 due to a lack of funds to purchase the Property. Poatsy Dep.

4 at 32; R.R. 358a. Poatsy testified that the Township has now connected the Perkiomen Trail and the Township Park, known as “Park-to-Perkiomen,” or “P2P Trail Connector.” Poatsy Dep. at 72-73; see also R.R. 354a. This trail system was expressly named in the Township’s 2007 Open Space and Recreation Plan. Poatsy testified that the trail on the Property will “loop from the [P]ark to Perkiomen to Spring Mountain” as “a wilderness walking trail” or “a dirt footpath.” Poatsy Dep. at 39, 74; R.R. 360a, 369a. This trail will provide “access” to the Park-to-Perkiomen Trail, which “satisfies the purpose of recreation.” Poatsy Dep. at 73; R.R. 369a. Poatsy testified that he did not know how much of the Property would be occupied by the trail. In his deposition, Township Supervisor O’Donnell confirmed that the Township condemned the Property “for recreational purposes, open space, [and] preservation of unique features associated with the [P]roperty.” O’Donnell Dep. at 19; R.R. 499a. A conceptual sketch of trailways on the Property was part of the 2007 Open Space and Recreation Plan.

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Bluebook (online)
In re: Condemnation of Property in Rem ~ Appeal of: J.L. Clemens & K.B. Clemens, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-condemnation-of-property-in-rem-appeal-of-jl-clemens-kb-pacommwct-2025.