Kelly v. Drab

13 Pa. D. & C.3d 652, 1980 Pa. Dist. & Cnty. Dec. LEXIS 549
CourtPennsylvania Court of Common Pleas, Montgomery County
DecidedFebruary 21, 1980
Docketno. 80-2245
StatusPublished

This text of 13 Pa. D. & C.3d 652 (Kelly v. Drab) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Montgomery County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kelly v. Drab, 13 Pa. D. & C.3d 652, 1980 Pa. Dist. & Cnty. Dec. LEXIS 549 (Pa. Super. Ct. 1980).

Opinion

SALUS, J.,

This case and a companion case for appointment of a borough councilman for Conshohocken Borough, No. 82 January 1980, arises from a local brush fire caused by the resignation of councilman Charles F. Kelly after his election and investiture shortly after the first of the year 1980.

The facts are that Councilman Kelly was elected in the November, 1979 General Election as councilman for the Fifth Ward. He joined three other Democrats on council making a four to three split on council. The Mayor of Conshohocken is Republican.

Councilman Kelly was sworn in on January 7, 1980, with others duly elected to Borough Council of Conshohocken. A reorganization meeting was held on January 9, 1980, and Councilman Kelly was elected President of Borough Council with Councilman Edward B. Drab as Vice-President. At that meeting and even after the meeting, several private citizens of the borough expressed strong reservations about Kelly’s ability to do the job as President of Council and further had strong criticisms of the redevelopment efforts in the borough. There may have also been some aspersions of Kelly selling out to the opposite party in order to get the presidency of council.

As a result of this furor and because of the upset to his wife and family, Councilman Kelly reviewed his personal situation and as a result, composed a letter of resignation to council dated January 10, 1980, and delivered a copy of same to the Democratic Chairman of Conshohocken, a copy to the Mayor, Francis Ruggiero, and slipped the original under the borough hall door for the secretary of the bor[654]*654ough. The resignation was “effective immediately.”

The word of the resignation spread rapidly and many called asking Kelly to reconsider, although he did not indicate he would do so. Upon notice of the resignation, Councilman Drab as Vice-President ordered the borough secretary to notice “his brethren” to a special meeting at 7:30 p.m. on Monday, January 14, 1980, in the Municipal Building “for consideration of and action upon the resignation of Charles F. Kelly.” The notice was advertised in the local paper and also sent to all councilmen save Kelly.

As a result of the furor over his resignation and the support for reconsideration, Kelly contacted the borough solicitor on January 11, 1980, concerning a rescission and/or a withdrawal of his resignation, its effect, and the wording of same in writing. A typewritten rescission and/or withdrawal of resignation was prepared, dated and signed January 14, 1980, and delivered and placed on the borough secretary’s desk on January 13, 1980.

The January 14, 1980 council meeting was assembled with three members present: Drab, Monacella and Ruggiero. Kelly had not been noticed and the three Democrats absented themselves. No quorum was present, so no action could be taken on the resignation and the rescission, if any. By then, of course, the rescission and/or withdrawal of resignation was known to all of council and the solicitor had been requested to give an opinion as to the resignation and withdrawal of same. Because of the lack of quorum, no business was transacted and a new special meeting was scheduled for January 21, 1980. Again no quorum was present and no action was taken although the [655]*655notice to this special meeting was for the express purpose of filling the vacancy. Again, the Democrats did not show.

In the meantime, Drab as Vice-President wanted a special meeting to discuss problems of the Washington Fire Company because the next regular meeting was not until February 13, 1980. None was held, nor was the regular meeting held on February 13, 1980, because of these suits. The instant suit, No. 80-2245 is for a declaratory judgment of whether Charles F. Kelly is councilman or not. The companion suit, No. 82, January 1980, is a petition to appoint Charles F. Kelly councilman, in the event he lost the declaratory judgment action.

The issue here is whether the tender of resignation “effective immediately” is self-executing or does it need an acceptance by formal action of council. A second issue is whether there was formal action at a public meeting of council accepting the resignation or some other type of acceptance of the resignation. A third issue is whether the tender was revoked before any formal action at a public meeting of council or some other type of acceptance of resignation.

The main body of Pennsylvania law likens municipal resignations to long-established contract law. The tender of resignation is considered the offer and the action of the municipal body thereon is the acceptance. Time after time resignations have been ineffective until formally accepted by the municipal governing body. See Edwards v. United States, 103 U.S. 471, 476 (1880); Com. v. Krapf, 249 Pa. 81, 84, 94 Atl. 553 (1915); Com. ex rel. Gast v. Kelly, 255 Pa. 475, 484, 100 Atl. 272 (1917); North Star District School Directors, 73 D. & C. 2d 27 (1975). An opposing point of view is [656]*656seen in Com. v. DeCinti, 6 D. & C. 3d 670 (1978), wherein it was held that a resignation was self-executing.

We feel the better view is that resignations require formal acceptance and are not self-executing. In the instant case the letter of resignation has language similar to the DeCinti minority view but differs in that there was a rescission or withdrawal of resignation. Further in DeCinti the person who resigned refused to act or attend meetings after resignation. In the instant case the resignation while “effective immediately” was effective immediately only after the resignation was accepted by the Borough Council of Conshohocken in public meeting and with a duly constituted quorum. The first meeting to consider the resignation was on January 14, 1980, and was called to consider the resignation and act upon it. Before this meeting was held, the rescission or withdrawal of resignation was submitted and, therefore, no vacancy was present for council to act upon. Further, there was no quorum at that January 14,1980 meeting to take any definitive action of any kind; since the present Borough Code and the former Borough Code are almost identical, prior precedent is as solid today as the Rock of Gibraltar. Clearly DeCinti is a sport restricted to its own facts.

Since no formal action was taken at a public meeting, and since no vacancy was present upon which to act, Charles F. Kelly is and has been a councilman of the Borough of Conshohocken representing the Fifth Ward. See 25 P.L.E. Municipal Corporations §63. The formal acceptance of a resignation can only be made by borough council as a whole with a duly constituted quorum. Without that, there is no duly constituted meeting.

[657]*657In addition to the above, the Open Meeting Law of July 19, 1974, P.L. 486, sec. 2, 65 P.S. §262, is as follows: “No formal action shall be valid unless such formal action is taken during a public meeting.” It is clear that in the instant case, no such action was taken and that the mere notice of the meeting was not an acceptance of the resignation because on January 14, 1980, the purpose of the meeting was to consider the resignation and act upon it. Neither was accomplished because of a lack of a quorum.

In passing, the court notes that the stare decisis in this case from the Supreme Court of the United States down to common pleas courts rationalizes resignations on contract principles.

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Related

Edwards v. United States
103 U.S. 471 (Supreme Court, 1881)
Steel v. Commonwealth
18 Pa. 451 (Supreme Court of Pennsylvania, 1852)
Commonwealth v. Krapf
94 A. 553 (Supreme Court of Pennsylvania, 1915)
Commonwealth, ex rel. Gast v. Kelly
100 A. 272 (Supreme Court of Pennsylvania, 1917)

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Bluebook (online)
13 Pa. D. & C.3d 652, 1980 Pa. Dist. & Cnty. Dec. LEXIS 549, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kelly-v-drab-pactcomplmontgo-1980.