Nicoletti v. Allegheny County Airport Authority

841 A.2d 156, 2004 Pa. Commw. LEXIS 32
CourtCommonwealth Court of Pennsylvania
DecidedJanuary 20, 2004
StatusPublished
Cited by11 cases

This text of 841 A.2d 156 (Nicoletti v. Allegheny County Airport Authority) 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
Nicoletti v. Allegheny County Airport Authority, 841 A.2d 156, 2004 Pa. Commw. LEXIS 32 (Pa. Ct. App. 2004).

Opinion

OPINION BY

Senior Judge KELLEY.

Carol M. Nicoletti (Condemnee) appeals from the order of the Court of Common Pleas of Allegheny County (trial court) overruling her preliminary objections to the Declaration of Taking filed by the Allegheny County Airport Authority (Authority) pursuant to the Pennsylvania Eminent Domain Code 1 and the Municipality Authorities Act of 1945. 2 We quash the appeal, vacate the trial court’s order, and dismiss the Declaration of Taking.

Condemnee owns the mineral rights in fee for a number of parcels of property located in Findlay Township, Allegheny County. Allegheny County owns the surface rights to these parcels in fee, through prior condemnation, as they are in close proximity to Pittsburgh International Airport. 3 On September 16, 1999, Allegheny County entered into the Airport Operation, Management and Transfer Agreement and Lease between Allegheny County, Pennsylvania and the Allegheny County Airport Authority (Lease Agreement) with the Authority. The Lease Agreement states, in pertinent part, that “[t]he County, at Closing, demises and lets unto the Authority and the Authority leases from the County, the Airports, including all lands, buildings, fixtures, improvements, structures, aviation easements, rights of access, and appurtenances pertaining thereto ... for the Demised Term [of 25 years] ... ”, and that the Authority has two options to extend the term of the Lease Agreement by two additional 25-year terms. Reproduced Record (R.R.) at 79a.

On November 9, 2001, the Authority’s Board of Directors adopted a Resolution authorizing the condemnation of the outstanding mineral rights owned by Con-demnee with respect to the subject par *158 cels. On May 10, 2002, the Authority filed a Declaration of Taking to condemn Con-demnee’s property which states, in pertinent part:

3. This Declaration of Taking was authorized by the following: a Resolution of the Board of Directors of the [Authority] adopted November 9, 2001
4. The purpose of this condemnation is to establish and maintain air navigation access and terminal facilities authorized by the Municipality Authorities Act of 1945 ...
5. A statement of the property and mineral interests being condemned and hereby taken (which are located in Moon and Findlay Townships, Allegheny County, Pennsylvania), is more particularly set forth in Exhibit “A” hereto attached. Also a plan of the property being taken and condemned is hereto attached and marked Exhibit “B”. The plan of the property being taken and condemned has been designated the “Mineral Estate Plan of Acquisition— Phase VI” and has also been filed with the Planning Department in the Office of the Recorder of Deeds of Allegheny County.
7. The purpose of this condemnation is to assure unto the [Authority] the absolute and unqualified fee simple title, free and clear of all liens and encumbrances, including all mineral estates, leasehold estates, easements and other interests of all record owners thereof, or any party having an interest therein (except as set forth in Exhibit “A”), the names of which owners and parties in interest and them respective interests condemned, if any, are more particularly set forth and tabulated in Exhibit “C” hereto attached.

R.R. at 1a-2a. 4

On June 13, 2002, Condemnee filed preliminary objections to the Authority’s Declaration of Taking, in which she alleged: (1) the stated purpose of the condemnation, i.e. the vesting of fee simple absolute title to the property in the Authority, cannot be achieved because Allegheny County owns the surface estate to the property in fee and the Authority merely has a posses- *159 sory interest under the terms of the Lease Agreement; (2) the condemnation is not for a public purpose as the Authority already has a sufficient interest in the property to maintain the airport and terminal facilities and is condemning the property to lease it to other private parties; and (3) the Authority’s use of its condemnation powers was fraudulent, arbitrary, capricious and done in bad faith.

Argument on the preliminary objections was conducted before the trial court. On January 9, 2003, the trial court entered an order and opinion disposing of Condemnee’s preliminary objections. Specifically, the court determined: (1) the Lease Agreement was the equivalent to the sale of the County’s interest in the property to the Authority for the term of the lease; (2) the Authority’s stated purpose to free the property from all encumbrances is a public purpose; and (3) the Authority’s condemnation of the outstanding interests in the land underlying the airport complex is not fraudulent, arbitrary, capricious or done in bad faith. As a result, the trial court issued an order overruling Condemnee’s preliminary objections to the Authority’s Declaration of Taking. Condemnee then filed the instant appeal in this Court. 5

In this appeal, Condemnee claims 6 : (1) the trial court erred in failing to dismiss the instant Declaration of Taking in that the County was an indispensable party to the proceedings as the owner in fee of the surface estate of the condemned property; (2) the trial court erred in determining that the Lease Agreement between Allegheny County and the Authority conveyed the County’s fee interest in the surface estate of Condemnee’s land; (3) the trial court erred in determining that the Authority’s condemnation was for a public purpose; and (4) the trial court erred in determining that the Authority’s condemnation was not fraudulent, arbitrary, capricious and done in bad faith.

As noted above, Condemnee first claims that the trial court erred in failing to dismiss the instant Declaration of Taking in that the County was an indispensable party to the proceedings as the owner in fee of the surface estate of the condemned property. 7 We agree.

Both the trial court below, and the Authority in this appeal, assert that the instant Lease Agreement conveyed a property interest in the airport land and structures to the Authority. It is true that leases do convey a proprietary interest in the property conveyed thereunder for the demised term. See, e.g., Stonehedge Square Limited Partnership v. Movie Merchants, Inc., 552 Pa. 412, 715 A.2d 1082 (1998); Adams Sanitation Co., Inc. v. Department of Environmental Protection, *160 552 Pa. 304, 715 A.2d 390 (1998); Commonwealth v. Monumental Properties, 459 Pa. 450, 329 A.2d 812 (1974).

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Bluebook (online)
841 A.2d 156, 2004 Pa. Commw. LEXIS 32, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nicoletti-v-allegheny-county-airport-authority-pacommwct-2004.