Lehigh Valley Properties, Inc. v. City of Allentown

CourtCommonwealth Court of Pennsylvania
DecidedFebruary 13, 2026
Docket1576 C.D. 2024
StatusUnpublished
AuthorCohn Jubelirer

This text of Lehigh Valley Properties, Inc. v. City of Allentown (Lehigh Valley Properties, Inc. v. City of Allentown) 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
Lehigh Valley Properties, Inc. v. City of Allentown, (Pa. Ct. App. 2026).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Lehigh Valley Properties, Inc., : Appellant : : v. : No. 1576 C.D. 2024 : Argued: December 8, 2025 City of Allentown :

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE MICHAEL H. WOJCIK, Judge (P.) HONORABLE MARY HANNAH LEAVITT, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY PRESIDENT JUDGE COHN JUBELIRER FILED: February 13, 2026

Lehigh Valley Properties, Inc. (LVP) appeals from the October 21, 2024 Order of the Court of Common Pleas of Lehigh County (trial court) granting the Motion for Summary Judgment (Motion) filed by the City of Allentown (City). Because we conclude that the trial court properly entered summary judgment in the City’s favor as to all four counts of LVP’s Third Amended Complaint, we affirm the trial court’s Order. I. BACKGROUND This Court previously summarized the facts underlying this case as follows:

[LVP] is the owner of 2.06 acres of vacant land located at 901 North Ivy Street, Allentown, Pennsylvania (Property) in the General Industrial District (I3 District) under the City’s Zoning Ordinance (Ordinance). In 2018, [LVP] filed a zoning application for the construction of two double-faced billboards on the Property – one static and the other digital. Billboards are permitted in the I3 District, but variances were needed to comply with the Ordinance’s distance requirements. Specifically, [LVP] proposed to place the static billboard 79 feet from a residential district, when the Ordinance requires at least 300 feet. [LVP] proposed to place the digital billboard 571 feet from another off-premises digital billboard, which was installed by the City, when the Ordinance requires 1,000 feet.[1] The zoning application was denied.

Lehigh Valley Props., Inc. v. City of Allentown Zoning Hearing Bd. (Pa. Cmwlth., No. 783 C.D. 2022, filed Apr. 4, 2024), slip op. at 1-2 (footnote and internal citation omitted). LVP appealed to the City’s Zoning Hearing Board (Board), which ultimately denied the appeal on April 5, 2021. In its decision,

[t]he Board . . . concluded that [LVP] failed to meet its burden of proving unnecessary hardship.[2] The Board explained that [LVP] did

1 The Ordinance provides an exception to the City’s zoning requirements for property owned by the City, as follows:

EXEMPTION FOR MUNICIPAL USES. This Ordinance shall not apply to any lot, existing or proposed building, use thereof, of any expansion thereof, owned, used or to be used by the City of Allentown or for a use authorized by the Mayor or City Council by virtue of a lease or other contract.

(Reproduced Record (R.R.) at 114 (emphasis added).) We note that the Reproduced Record does not comport with Pennsylvania Rule of Appellate Procedure 2173, Pa.R.A.P. 2173 (requiring that the pagination of reproduced records be in the form of an Arabic number followed by a small “a”). For ease, the Court will utilize the method used by the Reproduced Record. 2 A dimensional variance requires the applicant to establish unnecessary hardship. As this Court has explained:

Whether an applicant is seeking a dimensional or use variance, it must show unnecessary hardship will result if a variance is denied and that the proposed use will not be contrary to the public interest. It is only the stringency of the standard in proving an unnecessary hardship that varies, depending on whether a use or dimensional variance is sought.

To justify the grant of a dimensional variance, courts may consider multiple factors, including “the economic detriment to the applicant if the variance was denied, the financial hardship created by any work necessary to bring the building into strict (Footnote continued next page…)

2 not present substantial evidence that the Property could not be used for some purpose in conformity with the Ordinance. Additionally, [LVP] offered no evidence of any active, prolonged, and specific testing of the Property’s marketability. The Board also noted that [LVP]’s activities upon and use of the Property contributed, in part, to the difficulties of developing the Property.

Id., slip op. at 4. LVP appealed to the trial court, which affirmed the Board’s decision. LVP then appealed to this Court. During the pendency of the zoning matter, LVP initiated the present action by filing a pro se Complaint against the City and other defendants in the trial court on February 23, 2020, initially asserting claims of tortious interference with business relationships, nuisance, and civil conspiracy. LVP averred:

By virtue of the location of the [] City’s digital billboard[,] [LVP] is now, and has been, prevented from erecting a digital billboard, which deprived [LVP] of the best use of [its] [P]roperty. The [P]roperty was bifurcated by the City’s action creating a hardship for LVP. The highest and best use due to the bifurcation is billboards.

(Reproduced Record (R.R.) at 8-9.) After multiple rounds of preliminary objections and amended complaints, on November 23, 2020, LVP filed a Third Amended Complaint, the operative

compliance with the zoning requirements and the characteristics of the surrounding neighborhood.”

However, this Court consistently rejects requests for dimensional variances where proof of hardship is lacking. Where no hardship is shown, or where the asserted hardship amounts to a landowner’s desire to increase profitability or maximize development potential, the unnecessary hardship criterion required to obtain a variance is not satisfied even under the relaxed standard set forth [by our Supreme Court] in Hertzberg[ v. Zoning Board of Adjustment of the City of Pittsburgh, 721 A.2d 43 (Pa. 1998)].

Soc’y Hill Civic Ass’n v. Phila. Zoning Bd. of Adjustment, 42 A.3d 1178, 1186-87 (Pa. Cmwlth. 2012) (internal citations omitted).

3 complaint in this matter, against the City only. In its Third Amended Complaint, LVP asserted four causes of action: (1) de facto taking of LVP’s Property under the federal and state Constitutions; (2) nuisance in carelessly, negligently and/or intentionally interfering with LVP’s economic use of its Property; (3) unconstitutionality of the City’s Ordinance; and (4) violation of LVP’s civil rights under 42 U.S.C. § 1983 (Section 1983). After the trial court overruled the City’s Preliminary Objections to the Third Amended Complaint, the City filed an Answer and New Matter on October 18, 2021. Relevant to this appeal, in its New Matter, the City averred that “[LVP] failed to send the required notice of intention to make a claim against the City within six months after the cause of action accrued” as required by Section 5522(a)(1) of the Judicial Code, 42 Pa.C.S. § 5522(a)(1). (R.R. at 184.) The City also averred that “[t]he Eminent Domain Code[, 26 Pa.C.S. §§ 101-1106,] provides the exclusive method and practice governing de facto takings and require[d] [LVP] to file a Petition for the Appointment of a Board of Viewers[,] which [LVP] has failed to do.” (Id. at 186.) On December 29, 2022, while LVP’s appeal in the zoning matter was pending in this Court, the City filed its Motion in the trial court. LVP filed an Answer to the Motion on February 13, 2023. On June 15, 2023, the trial court issued an order deferring its decision on the Motion until this Court’s resolution of the zoning appeal. On April 4, 2024, this Court issued a decision in LVP’s zoning appeal. In affirming the trial court’s ruling upholding the Board’s decision, we concluded:

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