Leoni v. Whitpain Township Zoning Hearing Board

709 A.2d 999, 1998 Pa. Commw. LEXIS 181
CourtCommonwealth Court of Pennsylvania
DecidedMarch 24, 1998
StatusPublished
Cited by22 cases

This text of 709 A.2d 999 (Leoni v. Whitpain Township Zoning Hearing Board) 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
Leoni v. Whitpain Township Zoning Hearing Board, 709 A.2d 999, 1998 Pa. Commw. LEXIS 181 (Pa. Ct. App. 1998).

Opinion

LORD, Senior Judge.

Eugene and Marian Leoni appeal a Montgomery County Common Pleas Court decision sustaining the grant of a side yard setback zoning variance requested by Wayne and Sharon Schaible.

This case arises from the following undisputed circumstances. The Leonis own land abutting the rear of the Schaibles’ residential property in Whitpain Township. The Schai-bles sought to build on their property an addition to the side of their existing home for a bedroom and bathroom. The proposed addition would reduce the set-back of one of their side yards to 26 feet, where a minimum of 45 feet is required by the Township zoning ordinance. The ordinance also requires an aggregate of at least 100 feet considering both side yards; the addition would reduce the total side yards on the property to 78 feet.

The Schaibles thus applied to the Township Zoning Hearing Board for a variance from the side yard provisions of the ordinance. No objectors appeared and no objections were raised before the Board, which granted the variance following a hearing. The Leonis then appealed to the trial court, claiming that the Schaibles had not established any of the elements necessary for a variance in their hearing before the Board.

The Schaibles filed a motion to quash or dismiss the appeal or require a bond, asserting in part that the Leonis had not appeared or objected before the Board and lacked standing to appeal. In January 1997, after the parties briefed issues including that of standing, the Honorable Bernard A. Moore without opinion denied the motion, as well as a subsequent request for reconsideration. However, in July 1997, Judge Moore and the Honorable Kent H. Albright affirmed the Board’s decision on the basis that the Leonis lacked standing to appeal. ' The court issued an opinion reasoning that the Leonis did not object before the Board and, in any event, did not have a substantial interest qualifying them as “persons aggrieved.” The court also suggested that, had it reached the merits of the variance, it would still have upheld the Board’s decision because there was no legal error or manifest abuse of discretion. The Leonis now appeal to this Court.

The Leonis ask us to remand this ease for consideration of the substantive merits, raising two arguments as to why the trial court erred in holding they did not have standing to appeal. First, the Leonis submit that the trial court failed to follow the law of the case given the initial orders rejecting the Schaibles’ motion and denying reconsideration. They argue that those orders, although not accompanied by an opinion, implicitly decided the issue of standing to appeal in their favor. The Leonis assert that they were therefore entitled to rely on that decision and that the law of the case doctrine barred the court from later changing its ruling. See Goldey v. Trustees of the University of Pennsylvania, 544 Pa. 150, 675 A.2d 264 (1996); Farber v. Engle, 106 Pa.Cmwlth. 173, 525 A.2d 864 (1987).

The Schaibles respond that the law of the case doctrine is inapplicable here because the court’s initial rulings were made on a procedural motion, were not accompanied by an opinion, could have been made on any number of grounds, and were rendered by the same judge who issued the final determination—and who is always capable of reconsidering his own prior order. See Farber.

[1001]*1001We agree that the court did not err. The doctrine the Leonis seek to invoke provides that a trial judge should not overturn a decision made in the same ease by another judge. We have explained:

The general rule is that absent some new evidence, it is improper for a trial judge to overrule an interlocutory order entered by another judge of the same court involving the same issue.... The policy underlying this rule, sometimes erroneously referred to by the term “law of the case,” is that there must be some finality to the determination of all pretrial applications so that judicial economy and efficiency can be maintained.

Farber, 525 A.2d at 866. The Supreme has also considered “the rule that a judge should not overrule a decision of another judge of the same court in the same ease,” and reiterated the “the need for finality and the prevention of judge shopping.” Goldey, 544 Pa. at 152, 157, 675 A.2d at 265,267.

Here, the doctrine and the interests it is meant to protect are obviously not implicated, because Judge Moore took part in both decisions in question. Moreover, the court never affirmatively and specifically ruled that the Leonis had standing, so it cannot be rightly said that it reversed itself in eventually deciding that the Leonis did not have standing.1 Thus, there is no authority for holding there is a doctrine applicable to the circumstances of this case barring the trial court from reaching its final determination on standing. We therefore must reject the Leonis’ primary assertion.

The Leonis’ other argument here is that the court erred in its final decision because they had standing to appeal the Board’s decision despite their failure to appear or otherwise object before the Board. They claim that, since amended in 1988, the Pennsylvania Municipalities Planning Code (MPC), Act of July 31, 1968, P.L. 805, as amended, 53 P.S. §§ 10101-11202, no longer requires an appellant be a “party” or otherwise participate in zoning board proceedings. The Leonis maintain that an appeal by “persons aggrieved” is now always proper where, as here, the board did not ensure that the applicants’ hearing and proof were sufficient to meet the strict test for a variance.

The Schaibles reply that it is well settled that individuals cannot be heard on appeal if they had notice of a public zoning hearing and failed to object at that time. See In re Leopardi, 90 Pa.Cmwlth. 616, 496 A.2d 867 (1985), rev’d in part on other grounds, 516 Pa. 115, 532 A.2d 311 (1987). They argue that, despite the 1988 amendment to the MPC, the law of standing remains the same, and the MPC continues to limit appellants to “parties” before the Board. See, e.g., Gateside-Queensgate Co. v. Delaware Petroleum Co., 134 Pa.Cmwlth. 603, 580 A.2d 443 (1990). The Schaibles also note that the Leonis did not present any evidence that they were “persons aggrieved,” and claim the record in general would have been more developed, as the Leonis now demand it should have been, had the Leonis appeared. Finally, the Schai-bles argue that the Leonis faded to exhaust their administrative remedies by not appearing before the Board, and issues not raised before the Board are waived.

We resolve this remaining question in favor of the Schaibles as well and thus reject this appeal. Both parties here have addressed in their briefs the question of whether the Leonis are “persons aggrieved.” The Leonis contend that they are because they [1002]*1002own a neighboring property. The Schaibles contend the Leonis are not “persons aggrieved” because the side yard variance has no effect on the Leonis’ property, which abuts only on the rear and is distant from the residence.

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Bluebook (online)
709 A.2d 999, 1998 Pa. Commw. LEXIS 181, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leoni-v-whitpain-township-zoning-hearing-board-pacommwct-1998.