Maryland Casualty Co. v. Darby Township

20 Pa. D. & C.2d 543, 1959 Pa. Dist. & Cnty. Dec. LEXIS 340
CourtPennsylvania Court of Common Pleas, Delaware County
DecidedNovember 16, 1959
Docketno. 1230
StatusPublished
Cited by1 cases

This text of 20 Pa. D. & C.2d 543 (Maryland Casualty Co. v. Darby Township) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Delaware County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maryland Casualty Co. v. Darby Township, 20 Pa. D. & C.2d 543, 1959 Pa. Dist. & Cnty. Dec. LEXIS 340 (Pa. Super. Ct. 1959).

Opinion

Sweney, P. J.,

— This is a declaratory judgment action, in which the trial judge entered an order in favor of defendant and exceptions filed by plaintiffs have been argued before the court en banc.

The facts are not in dispute. The Township of Darby entered into a contract with one W. J. Gregory, Jr., for certain road repairs on a unit basis of $7.77 per square yard, at an estimated aggregate cost of $2,500. In anticipation of extra work and possible State aid, the township allocated the sum of $4,000 in its budget for these repairs. The Maryland Casualty Company, hereinafter called Maryland, issued its performance bond in the sum of $2,500 as surety for Gregory. Gregory defaulted on his contract prior to the commencement of any work. Upon notice of Gregory’s default, Maryland entered into a contractual relationship with Carl Atran, t/a R. & A. Construction Company, to perform the services set forth in the Gregory contract. A severe winter intervened between the time of Gregory’s default and Maryland’s contract with Atran. It played havoc with the roads, and when the work was [545]*545started, it became immediately apparent that the repairs would have to be far more extensive than had been contemplated at the time the Gregory contract was let. Instead of taking the matter up with the township officials for some possible adjustment, Atran proceeded to perform his services, not only exceeding the estimated $2,500, but going far beyond the appropriations in the township budget for the work.

Neither Maryland nor Atran notified the township when work had been completed in the amount of $2,500, which was the original contract estimate, and the limit of Maryland’s liability under its performance bond. The township did not appropriate any additional funds for the work, and it took no official action authorizing a larger expenditure for road purposes.

It is not disputed that a great amount of work was done, that an abundance of materials was furnished and that the services were performed in a workmanlike manner. The township officials observed the work being done, and from time to time verbally directed Atran’s work. All was well until the bills were submitted totaling $19,829.04. The Township of Darby refused to pay any amount in excess of $2,500, unless such payment was approved by the court.

The foregoing facts raise the following legal issue:

May the court of common pleas order the Township of Darby to pay the sum of $19,829.04, for road repairs performed for the township under a contractual arrangement between a bonding company and the contractor, when the cost of said repairs is in excess of the estimated total aggregate price of the original contract let by the township, and is in excess of the amount of money specifically appropriated in the township budget for the repairs, upon a showing by the bonding company and the contractor that: (1) The work was necessary; (2) was done in a workmanlike manner; (3) the township officials were aware of the [546]*546work and service being performed; (4) verbal instructions were given from time to time by the superintendent of highways of the township and the chairman of the committee on streets and.highways of the township to the contractor to do and perform such work as was necessary to repair the streets and highways at the places and for the prices set forth in the original contract; and (5) that additional necessary repairs beyond the scope of the original contract were made?

We are forced to give a negative answer to this question.

Plaintiffs rely on section 1702 of the First Class Township Code of June 24, 1931, P. L. 1206, to sustain their request that the court order payment of this claim. This section, 53 PS §56702, reads as follows:'

“No work shall be hired to be done, no materials purchased, no contracts made, and no orders issued for the payment of any moneys, by the authorities of any township, in any amount which will cause the sums appropriated to specific purposes to be exceeded. No change in the purpose of the appropriations shall be made unless by an ordinance, which shall set out the reasons for and character of such change. If any work shall be done for or materials furnished to any township contrary to the provisions of this section, the township commissioners are hereby prohibited from authorizing payment therefor as a moral obligation or otherwise, unless ordered or directed so to do by the court of common pleas or the court of quarter sessions of the county in which such township is situate.”

However, from the wording of this section, it is evident that this section applies only in case a contract has been negotiated by township authorities and the cost of goods or services exceed the contract or the sums appropriated in the budget therefor hut nevertheless bear a reasonable relationship to the under[547]*547estimated expenses: Upper Darby Township’s Petition, 51 D. & C. 88, 92 (1944).

Since there is no contract between the township and either of plaintiffs, the First Class Township Code of June 24, 1931, P. L. 1206, sec. 1802, as amended by Act of May 17, 1957, P. L. 168, 53 PS §56802, is applicable. The section reads: “All contracts or purchases made by any township, involving the expenditure of over one thousand dollars . . . shall be in writing. . . . Any contract made in violation of the provisions hereof shall be void. . ..” Thus, a township is prevented from expending money by oral negotiations.

We also call attention to section 1703 of the First Class Township Code, 53 PS §56703, which reads as follows: “No contracts, hirings, or purchases made, or orders or warrants issued, not provided for by an appropriation by the township commissioners as is required by law, or which would cause any appropriation to be exceeded, shall be valid.”

We find it significant that the foregoing section does not authorize the court to order payment for work done contrary to the provisions of this section. It strengthens our view that section 1702, supra, is limited to contract actions by the commissioners, under circumstances there noted.

The conduct, dealings and actions of public officials are strictly controlled and regulated by legislative enactments designed to protect the taxpayers of the community. One dealing with a municipality is bound to recognize the limitations surrounding municipal contracts.

It is clear from the testimony that at the time of the letting of the Gregory contract, the aggregate estimate of $2,500 was a fair one. It is equally clear that at the time Maryland and Atran entered into their contract for assumption of the Gregory contract the roads of the township were in need of far more repair [548]*548work than had been originally considered necessary, and as plaintiffs state in their argument, it was “immediately apparent that the defective areas were more extensive than had been originally assumed”. As the bills presented show, the cost of the repairs not only exceeded the aggregate amount that had been estimated, but went J;ar beyond the sum of money appropriated in the township budget for them. Had Maryland asked the township commissioners to formally approve the proposed work by Atran, the commissioners could have approved only that amount of work which would exhaust the funds allocated in the budget for it.

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Related

Maryland Casualty Co. v. Darby Township
399 Pa. 492 (Supreme Court of Pennsylvania, 1960)

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Bluebook (online)
20 Pa. D. & C.2d 543, 1959 Pa. Dist. & Cnty. Dec. LEXIS 340, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maryland-casualty-co-v-darby-township-pactcompldelawa-1959.