Lehigh-Northampton Airport Authority v. Lehigh County Board of Assessment Appeals

889 A.2d 1168, 585 Pa. 657
CourtSupreme Court of Pennsylvania
DecidedDecember 30, 2005
Docket185-193 MAP 2004
StatusPublished
Cited by13 cases

This text of 889 A.2d 1168 (Lehigh-Northampton Airport Authority v. Lehigh County Board of Assessment Appeals) is published on Counsel Stack Legal Research, covering Supreme Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lehigh-Northampton Airport Authority v. Lehigh County Board of Assessment Appeals, 889 A.2d 1168, 585 Pa. 657 (Pa. 2005).

Opinion

OPINION

Justice SAYLOR.

The question presented in this appeal is whether, and to what extent, real property owned by a municipal authority *662 formed in accordance with the Municipality Authorities Act is immune from local real estate taxation.

The Lehigh-Northampton Airport Authority (the “Authority”) was incorporated in 1968 by Lehigh and Northampton Counties pursuant to the Municipality Authorities Act of 1945. 1 The Authority’s board of governors consists of 19 members, ten appointed by Lehigh County, and nine appointed by Northampton County. Neither the Commonwealth of Pennsylvania, nor its officers, officials, or legislature appoints any member of the board of governors. The Authority’s mission, as set forth in its articles of incorporation, is “to plan and provide for the current and future air transportation needs of the Lehigh Valley Market Area by constructing, maintaining, and operating safe, efficient, modern and attractive airport facilities.” To that end, the Authority owns and operates the Lehigh Valley International Airport (the “Airport”), located -within the boundaries of both Hanover Township and the Catasauqua Area School District, both of which are in Lehigh County. In connection -with airport operations, the Authority owns and maintains various parcels of real property having a variety of uses, including, inter alia, aircraft hangars, public aircraft parking aprons, air cargo processing centers, United States Customs facilities, United States Postal Service facilities, air courier facilities, helicopter training areas, airplane maintenance areas, areas for the storage of runway snow removal equipment, facilities for package sorting *663 and ground operations, areas for the storage of construction materials, areas for the training of firefighters, and a storm water detention basin.

Upon the Authority’s filing of applications for tax immunity or exemption in 1999, the Lehigh County Board of Assessment Appeals granted partial relief by granting tax-exempt status to two of the Authority’s twenty-one properties. The Authority filed ten appeals to the common pleas court, and the affected taxing bodies — Lehigh County, Hanover Township, and Catasauqua Area School District (collectively with the Board of Assessment Appeals, “Appellees”) — intervened. The common pleas court consolidated the appeals for all purposes, including trial.

During the proceedings in the trial court, the Authority sought blanket tax immunity or, alternatively, tax exemption for the ten subject properties. 2 The Authority filed a motion for summary judgment, raising both of these claims. The trial court bifurcated proceedings on the motion, opting first to address whether the Authority enjoyed tax immunity, and leaving for later the question of tax-exempt status as to each individual parcel. On the immunity issue, Appellees maintained that this Court’s decision in Pennsylvania State University v. Derry Township Sch. Dist., 557 Pa. 91, 731 A.2d 1272 (1999) (“Penn State”), is directly relevant to the present matter. In Penn State, this Court held that the Milton S. Hershey Medical Center of the Pennsylvania State University (“PSU”) was not immune from real estate taxes because only a minority of the individuals on PSU’s governing board were members of, or appointed by, the Commonwealth government. Appellees indicated that, because all of the members of the Authority’s governing board are appointed by Lehigh County or Northampton County, the same result should obtain here as in Penn State. It further argued that, although authorities *664 created pursuant to the Act are considered Commonwealth entities for some purposes, the Authority should nonetheless not be deemed a Commonwealth entity for purposes of property tax immunity.

The Authority countered that Penn State’s Commonwealth-control test should not be deemed to apply presently, because that case did not involve an entity created under the Municipality Authorities Act, and moreover, in post-Penn State disputes, the Commonwealth Court has opted not to utilize that standard outside of the educational-institution setting. See SEPTA v. Board of Revision of Taxes, 777 A.2d 1284 (Pa.Cmwlth.2001), aff 'd 514 Pa. 707, 833 A.2d 710 (2003); Dauphin County General Auth. v. Dauphin County Bd. of Assessments, 768 A.2d 895 (Pa.Cmwlth.2000). Finally, the Authority maintained that its status as part of the Commonwealth rather than as a creature of Lehigh County or Northampton County is illustrated by its relationship to the Pennsylvania Department of Transportation’s Bureau of Aviation, which licenses the Airport for operation.

By order dated June 6, 2002, the trial court denied the Authority’s motion for summary judgment as to tax immunity. In support of its decision, the court filed a memorandum opinion on June 18, 2002, in which it cited to Penn State as setting forth the applicable test for determining whether an entity is an agency or instrumentality of the Commonwealth for purposes of real estate tax immunity, quoting that decision as follows:

With regard to immunity from real estate taxes, we view the pivotal factor to be whether the institution’s real property is so thoroughly under the control of the Commonwealth, that, effectively, the institution’s property functions as Commonwealth property.... When determining whether an institution is an agency or instrumentality of the government, we must consider whether the Commonwealth has majority control of the board.

Trial Court Op. (June 18, 2002), at 7 (quoting Penn State, 557 Pa. at 96, 731 A.2d at 1274). Noting that this Court has never expressly limited the Commonwealth-control standard to edu *665 cational institutions only, the trial court construed the above passage broadly to apply to the present case notwithstanding the Authority’s status as a Commonwealth entity under the Municipality Authorities Act; in this respect, the court suggested that, to the extent the Commonwealth Court’s post-Perm State jurisprudence conflicted with the above pronouncement in Penn State, the latter must be deemed to control as representing the view of the state’s highest appellate court. See id. at 9-10.

Subsequently, on July 2, 2002, the case proceeded to trial de novo on the issue of tax exemption, at which evidence concerning the uses of the subject properties was adduced. During these proceedings, the status of one of the ten parcels was resolved by agreement of the parties; accordingly, that property is not at issue here.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
889 A.2d 1168, 585 Pa. 657, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lehigh-northampton-airport-authority-v-lehigh-county-board-of-assessment-pa-2005.