Passage of Zoning Ordinance

51 Pa. D. & C.2d 477, 1970 Pa. Dist. & Cnty. Dec. LEXIS 311
CourtPennsylvania Court of Common Pleas, Delaware County
DecidedOctober 30, 1970
Docketno. 117
StatusPublished

This text of 51 Pa. D. & C.2d 477 (Passage of Zoning Ordinance) 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
Passage of Zoning Ordinance, 51 Pa. D. & C.2d 477, 1970 Pa. Dist. & Cnty. Dec. LEXIS 311 (Pa. Super. Ct. 1970).

Opinion

deFURIA, J.,

We have before us the township’s motion to quash the appeal of ap[478]*478pellants to this court taken pursuant to the provisions of the Pennsylvania Municipalities Planning Code (hereinafter referred to as MPC).

The township maintains that procedural questions involved in the adoption of an ordinance must be challenged in the Court of Quarter Sessions (now the Court of Common Pleas) in accordance with the provisions of the Second Class Township Code of May 1, 1933, P. L. 109, as amended, cl. XLI of art. VII, sec. 702, 53 PS §65741.

Appellants and the intervenor hold that the appeal to this court was properly filed under section 915 of the MPC, 53 PS §10915, which became effective on January 1, 1969.

Our court has for disposition several cases from various municipalities dealing with the identical or closely related issues.

In Thomas J. Bradley et al. v. Township of Radnor, misc. Q. S. dkt. no. A31, p. 77, December sessions, 1969, opinion filed October —, 1970, plaintiffs, seeking to attack procedural defects in the adoption of a zoning ordinance, filed a complaint with this court under the provisions of the First Class Township Code. There was no objection by the township or the intervenor, but the court felt constrained to note that the procedure adopted by plaintiffs was correct, since it is questionable that consent or nonobjection can confer jurisdiction.

In Ardmore Manor Civic Association v. Township of Haverford, 51 D. & C. 2d 417, we dismissed prehminary objections contesting the propriety of a complaint, pursuant to the First Class Township Code, filed with our Court of Common Pleas objecting to the procedure used by Haverford Township, a first class township, in adopting a zoning ordinance.

The instant case involves a second class township, with an appeal filed to our court under the provisions [479]*479of the MPC questioning the procedure involved in the adoption of a zoning ordinance.

Since, as we later note, the appeal provisions of the First Class Township, Second Class Township and Borough Codes are cognate and correlative, our decision in the Haverford Township case, supra, is determinative.

On August 4, 1969, the Board of Supervisors of Thombury Township adopted, effective August 9, 1969, an amendment to its zoning ordinance creating a new commercial district.

On August 29, 1969, appellants filed an appeal with the zoning hearing board of the township pursuant to section 910 of the MPC, 53 PS §10910, raising several alleged procedural irregularities: lack of a comprehensive plan; improper and lack of notices; improper advertisement; lack of a planning agency and submission of the proposed amendment to it prior to the public hearing.

Appellants do not dispute that their allegations relate exclusively to alleged defects in the process of enactment of the amendment.

The zoning hearing board held a public hearing on October 27, 1969, and, on December 9, 1969, issued its report and findings of fact with respect to the procedure followed.

In its last finding, the zoning hearing board indicated its uncertainty on the question whether or not it had a right to hold such hearing, and reserved that question for determination by the court.

On January 5, 1970, appellants filed the within appeal with the Court of Common Pleas of Delaware County, in which they allege that the zoning amendment was illegal, arbitrary and contrary to law in that it was:

(a) Not passed pursuant to any comprehensive plan, and that such a plan did not exist;

[480]*480(b) Passed without proper and adequate notice;

(c) Enacted despite lack of a township planning commission as required by the MPC;

(d) Was enacted without submission to a planning agency 30 days prior to the public hearing, as required by the MPC.

Therefore, of record, we find:

1. The adoption of a zoning amendment by a second class township on August 9, 1969 (effective date).

2. An appeal to the Court of Common Pleas on January 5, 1970, pursuant to the MPC, raising alleged procedural defects in the process of enactment of the amendment.

The township avers that the appeal procedure used by appellants under the MPC, via the zoning hearing board and then to this court was improper and illegal; that for procedural irregularities a complaint must be filed directly in the Court of Common Pleas within 30 days of the action of the township.

The confusion in this and like cases arises because the comprehensive new planning code overlaps, changes and repeals certain provisions of the municipal codes.

As we pointed out in the Haverford case, the Supreme Court in Roeder v. Hatfield Borough Council, 439 Pa. 241 (1970), decided July 2, 1970, and reported in the September 4, 1970, Advance Reports, explicated the provisions of the MPC and the various municipal codes in reference to the proper method of attacking procedural and substantive defects in zoning amendments.

Essentially, Roeder, at page 246, indicates that:

1. For challenges to the procedure involved in the adoption of an ordinance, the appropriate section of the municipal code must be followed. A complaint must be filed with the Court of Common Pleas within [481]*48130 days. “The purpose of sections such as 1502 (First Class Township Code), 702 (Second Class Township Code) and 1010 (Borough Code) is to provide a fast and efficient method of questioning the procedure involved in the adoption of an ordinance.”

2. For challenges to the substantive validity of an ordinance, the procedure set forth in section 910 of the MPC must be followed by appealing to the Court of Common Pleas when the case is ripe for judicial intervention, i.e., usually, after the issuance of a building permit.

3. The function of the zoning hearing board is “to prepare a record if special issues of fact or interpretation exist which have not been determined at a hearing before another competent agency or body”: Roeder v. Hatfield Borough Council, supra, p. 247. These issues must be raised before the zoning board within 30 days of the effective date of the ordinance. (MPC, sec. 915.)

“Even though the MPC thus creates a statute of limitations, it does not create a formal procedure by which such questions may be raised. As section 910 explicitly states . . . the (zoning) board has no power to pass on the validity of an ordinance . . .”: Footnote, p. 246, Roeder v. Hatfield Borough Council, supra.

Therefore, it would appear that:

For procedural defects, a complainant must follow the municipal code, here section 702 of the Second Class Township Code, and file his complaint within 30 days of the effective date of the ordinance in the Court of Common Pleas. He may also, if he desires to raise special issues of fact or interpretation, appeal to the zoning hearing board, within the same time limitation, which board will then prepare a record for consideration by the court.

For substantive defects, a complainant must file [482]*482his appeal with the Court of Common Pleas at any time such issue is ripe for determination; ordinarily, when a building permit is issued.

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Related

Unger v. Hampton Township
263 A.2d 385 (Supreme Court of Pennsylvania, 1970)
Roeder v. Hatfield Borough Council
266 A.2d 691 (Supreme Court of Pennsylvania, 1970)

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Bluebook (online)
51 Pa. D. & C.2d 477, 1970 Pa. Dist. & Cnty. Dec. LEXIS 311, Counsel Stack Legal Research, https://law.counselstack.com/opinion/passage-of-zoning-ordinance-pactcompldelawa-1970.