Misingwa Land Trust v. Board of Commissioners of the County of Beaver

CourtCommonwealth Court of Pennsylvania
DecidedJune 17, 2026
Docket944 & 1162-1169 C.D. 2023
StatusPublished
AuthorLeavitt

This text of Misingwa Land Trust v. Board of Commissioners of the County of Beaver (Misingwa Land Trust v. Board of Commissioners of the County of Beaver) 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
Misingwa Land Trust v. Board of Commissioners of the County of Beaver, (Pa. Ct. App. 2026).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Misingwa Land Trust, : CASES CONSOLIDATED Appellant : : v. : Nos. 944 and 1162-1169 C.D. 2023 : Argued: November 6, 2025 Board of Commissioners of the County : of Beaver, Sitting as the Beaver County : Board of Assessment Revision; Beaver : County; South Beaver Township; : Darlington Township; and Blackhawk : School District :

BEFORE: HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE STACY WALLACE, Judge HONORABLE MARY HANNAH LEAVITT, Senior Judge

OPINION BY SENIOR JUDGE LEAVITT FILED: June 17, 2026

Misingwa Land Trust (Land Trust) appeals the orders of the Court of Common Pleas of Beaver County (trial court) that denied its application for a real estate tax exemption as a purely public charity. The trial court held that the Land Trust, established for the conservation of land and preservation of historic resources, did not demonstrate that it was a purely public charity within the meaning of Article VIII, Section 2(a)(v) of the Pennsylvania Constitution and, thus, tax exempt. PA. CONST. art. VIII, §2(a)(v).1 On appeal, the Land Trust argues that the trial court erred because the record evidence, which was not rebutted, demonstrated compliance with each of the constitutional and statutory requirements for a tax exemption as a purely public charity. Concluding that the trial court erred in its application of the constitutional standards for a purely public charity, we vacate its

1 The full text of this provision of the Pennsylvania Constitution is set forth, infra, in the body of the opinion. orders and remand for further proceedings, consistent with this opinion, on both the constitutional and statutory requirements for a tax exemption. Background At issue are seven parcels of land located in the Blackhawk School District (School District) in Beaver County (County). Parcel Nos. 77-120-0100.P00, 77-120-0100.N00, and 77-120-103.001 are located in South Beaver Township; Parcel Nos. 58-120-0117.P00, 58-120-0117.N00, 58-120-0118.000, and 58-120- 0118.001 are located in Darlington Township (collectively, Properties). In size, each parcel ranges from 16 to 100 acres, and they consist of vacant woodlands, with the exception of one building, a former industrial brick plant, located on Parcel No. 58- 120-0118.001. Portions of the Properties are enrolled in the “Clean and Green” program2 and have qualified for preferential assessments under the Pennsylvania Farmland and Forest Land Assessment Act of 1974.3 The Land Trust acquired the Properties between May 2020 and September 2021. The Land Trust is a Pennsylvania nonprofit corporation established for the purposes of “conservation and preservation of lands having historical significance or [that] constitute an open space or natural area and to promote same to the general public providing access to and disseminating information about the

2 Notably, Parcel Nos. 58-120-0117.P00 and 58-120-0117.N00 share the same boundaries, with the “P00” designation being the “Clean and Green” parcel of the bounded property. Likewise, Parcel Nos. 77-120-0100.P00 and 77-120-0100.N00 share the same boundaries, with the “P00” designation being the “Clean and Green” parcel of the bounded property. 3 Act of December 19, 1974, P.L. 973, as amended, 72 P.S. §§5490.1-5490.13 (commonly referred to as “Act 319” or “Clean and Green Act”), which established the Clean and Green program. Preferential assessments apply to land devoted to agricultural use, agricultural reserve, or forest reserve. Section 3(a) of Act 319, 72 P.S. §5490.3(a). Roll-back taxes may be due “for a change in use of the land, a change in ownership of a portion of the land, or any type of division or conveyance of the land.” Section 4(c) of Act 319, 72 P.S. §5490.4(c). 2 land.” Articles of Incorporation, ¶11; Reproduced Record at 383 (R.R. __).4 The Articles of Incorporation preclude the corporation’s officers and directors from realizing a pecuniary benefit from Land Trust operations. Articles of Incorporation, ¶14; R.R. 384. The Land Trust has been granted an exemption from federal taxation under Section 501(c)(3) of the Internal Revenue Code, 26 U.S.C. §501(c)(3). In the event of a dissolution of the corporation, the assets of the Land Trust must be distributed to another Section 501(c)(3) nonprofit organization. Articles of Incorporation, ¶16; R.R. 385. In its “Application for Recognition of Exemption under Section 501(c)(3) of the Internal Revenue Code,” i.e., Form 1023, the Land Trust described its purpose as follows: The purpose of [the Land Trust] is to identify, preserve, and, when needed, remediate lands of historical significance that were inhabited and used by American Indian cultures from the Adena and Hopewell cultures through the Eastern Woodland tribes and nations until 1800. These goals will be accomplished through public and private fundraising activities that will allow [the Land Trust] to acquire lands in and around Western Pennsylvania and Eastern Ohio. It is anticipated that remediation of blighted lands will be accomplished through partnership with regional universities, as well as with conservation organizations that work in remediation and historical preservation.

R.R. 460. In 2021, the Land Trust petitioned the Beaver County Board of Assessment Revision (Board of Assessment) for a real estate tax exemption for the

4 Pennsylvania Rule of Appellate Procedure 2173 requires the pages of the reproduced record to be separately numbered with Arabic figures followed by a small “a.” See Pa.R.A.P. 2173. This opinion uses the pagination as it appears in the reproduced record filed with this Court. 3 Properties, beginning with the 2022 tax year. By orders dated January 4, 2022, and February 2, 2022, the Board of Assessment denied the petitions. The Land Trust filed nine appeals to the trial court.5 The trial court consolidated the appeals for a de novo trial. At the evidentiary hearing on February 10, 2023, the Land Trust president, Thomas Keiser, II (Keiser), testified. He explained that he and his father, Thomas Keiser, Sr., the incorporators of the Land Trust, serve without compensation. In addition to the Properties at issue, the Land Trust owns another property located in Lawrence County, Pennsylvania. The Properties are located near state game lands that are intersected by the North County Trail that stretches from Maine to North Dakota. Two community parks, Darlington Park and Sahli Park, are close to the Properties. Keiser testified that the Properties “are historically significant” because they served as hunting grounds for the Native American tribes that had once inhabited the area. Notes of Testimony, 2/10/2023, at 58 (N.T. __); R.R. 152. Keiser testified that a “notable” “turkey [hunting] camp” of Tanaghrisson, a Seneca chief, “was located along the north fork of the Little Beaver [River] in this immediate area.” N.T. 58-59; R.R. 152. The camp was located at or near the brick plant located on Parcel No. 58-120-0118.001. Keiser testified that the Native American activity along the fork of the Little Beaver River involved notable historic persons and events.

5 It appears that several of these appeals were filed in duplicate. See R.R. 34, 47, 112, 123 (Petition for Allowance of Appeal, Docket No. 10154-2022, and Petition for Allowance of Appeal, Docket No. 10219-2022, both related to Parcel No. 58-120-0118.000; Petition for Allowance of Appeal, Docket No. 10151-2022, and Petition for Allowance of Appeal, Docket No. 10220-2022, both related to Parcel No. 58-120-0118.001). In short, the nine appeals concern seven parcels.

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Misingwa Land Trust v. Board of Commissioners of the County of Beaver, Counsel Stack Legal Research, https://law.counselstack.com/opinion/misingwa-land-trust-v-board-of-commissioners-of-the-county-of-beaver-pacommwct-2026.