Pignetti, G & J, h/w, Aplts. v. PennDOT

Supreme Court of Pennsylvania·Decided April 25, 2025·No. 27 EAP 2023·Published

Opinion

[J-11A-2024 and J-11B-2024]

IN THE SUPREME COURT OF PENNSYLVANIA EASTERN DISTRICT

TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, McCAFFERY, JJ.

GIANNI PIGNETTI AND JENNIFER : No. 26 EAP 2023 PIGNETTI, :

: Appeal from the Order of Appellants : Commonwealth Court entered on : 2/6/2023 at No. 1196 CD 2021, : reversing the Order dated 10/6/2021 v. : in the Court of Common Pleas, : Philadelphia County, Civil Division at : No. 01078 April Term, 2021.

COMMONWEALTH OF PENNSYLVANIA, :

DEPARTMENT OF TRANSPORTATION, : ARGUED: May 15, 2024 :

Appellee :

GIANNI PIGNETTI AND JENNIFER : No. 27 EAP 2023 PIGNETTI, :

: Appeal from the Order of Appellants : Commonwealth Court entered on : 2/6/2023 at No. 1197 CD 2021, : reversing the Order dated 10/6/2021 v. : in the Court of Common Pleas, : Philadelphia County, Civil Division at : No. 01078 April Term, 2021.

COMMONWEALTH OF PENNSYLVANIA, :

DEPARTMENT OF TRANSPORTATION, : ARGUED: May 15, 2024 :

Appellee :

OPINION

JUSTICE WECHT DECIDED: April 25, 2025 This Court long has recognized that the condemnation of one parcel may affect the use and the value of another to such an extent that the two parcels should be valued

as one.1 We have applied this “plottage” principle to both contiguous and noncontiguous parcels.2 For the sound goal in eminent domain is to ensure just compensation to an owner whose land is condemned.3 It is intuitive that, in property valuation as in life, the whole sometimes is worth more than the sum of its parts. Over sixty years ago, the General Assembly saw fit to codify this long-standing common-law principle in our Eminent Domain Code (“the Code”).4 With noncontiguous parcels, plottage valuation applies when “a part of several noncontiguous tracts in substantially identical ownership which are used together for a unified purpose is condemned.”5 In this case, the Commonwealth Court ruled that two noncontiguous parcels were not “used together for

1 See Appeal of Elgart, 149 A.2d 641, 643 (Pa. 1959) (“Even where there are no actual physical improvements an increment of value (plottage value) arises as a consequence of combining two or more sites, thereby developing a single site having a greater value than the aggregate of each when separately considered.”); Plottage, BLACK’S LAW DICTIONARY (10th ed. 2014) (“The increase in value achieved by combining small, undeveloped tracts of land into larger tracts.”). 2 Cf. Potts v. Pa. & S.V.R. Co., 13 A. 291, 293 (Pa. 1888) (“[I]solated cases may perhaps exist . . . where although the lands are not in fact contiguous, yet the uses to which they are applied, respectively, are in their nature so intimate and dependent, one upon the other, that an injury to one must necessarily be taken as an injury to the whole taken together.”). 3 See 26 Pa.C.S. § 701 (providing that “[a] condemnee shall be entitled to just compensation for the taking, injury or destruction of the condemnee’s property”). 4 See 26 P.S. § 1-605 (repealed 2006). The 1964 Eminent Domain Code was enacted by the Act of June 22, 1964, Special Sess., P.L. 84, (codified at 26 P.S. §§ 1- 101 to 1-903). The 1964 Code was repealed by Section 5(2) of the Act of May 4, 2006, P.L. 112, No. 34 (“Act 34”). Act 34 repealed the prior iteration of the Code and enacted the consolidated Eminent Domain Code at 26 Pa.C.S. §§ 101-1106. Section 705 of the consolidated Code replaced former Section 1-605 and included the same language pertaining to unity of use that is central to this appeal. 5 26 Pa.C.S. § 705 (emphasis added).

a unified purpose,” and it reversed the trial court’s ruling to the contrary. We believe the trial court ruled correctly. Accordingly, we reverse the Commonwealth Court’s order.

I. Case History

On February 28, 2019, pursuant to Section 302 of the Code,6 PennDOT filed in the trial court a declaration of taking (“Declaration”) in connection with a project to improve Interstate 95 in Philadelphia. PennDOT thereby condemned, inter alia, a portion of property located at 1035-1041 North Front Street and 4-18 Richmond Street (“Parcel 44”) and all of the property located at 22 Richmond Street (“Parcel 45”).7 The Pignettis owned Parcel 44 jointly as husband and wife, while Mr. Pignetti owned Parcel 45 individually. A third, “unoccupied and unused sliver of land no more than several square feet in area” separates the Parcels, rendering them noncontiguous.8 The Pignettis did not contest the taking itself. Instead, on April 14, 2021, they filed a petition (“Petition”) in the trial court seeking the appointment of a board of viewers (“Board”) pursuant to Section 502(a) of the Code9 to determine just compensation for PennDOT’s taking. PennDOT filed preliminary objections and a response in opposition

6 26 Pa.C.S. § 302. 7 We refer to Parcels 44 and 45 collectively as “the Parcels.” 8 Trial Ct. Op., 10/6/2021, at 5 n.1 (hereinafter “T.C.O.”). According to the Pignettis, at their narrowest approach, the Parcels are separated by only five to ten feet. Pignettis’ Br. at 4. The Commonwealth Court described the third parcel as “a trapezoidal-shaped parcel of land [that] separates the easterly line of Parcel 44 from the westerly line of Parcel 45 by approximately 10 feet at their closest points and 90 feet at their farthest points.” Pignetti v. PennDOT, 1196 C.D. 2021 and 1197 C.D. 2021, 2023 WL 1773952, at *1 (Pa. Cmwlth. Feb. 6, 2023) (hereinafter “Pignetti”). PennDOT does not dispute these descriptions. 9 26 Pa.C.S. § 502(a) (providing that “[a] condemnor, condemnee or displaced person may file a petition requesting the appointment of viewers”).

to the Petition, asserting: (1) that the Pignettis waived their damages claim by failing to file preliminary objections to PennDOT’s Declaration; and (2) that there was not “substantially identical ownership”10 between the Parcels so as to entitle the Pignettis to have the Parcels valued together as one, because PennDOT had an ownership interest in Parcel 45 by virtue of an easement.11 The Pignettis filed an answer to PennDOT’s preliminary objections, disputing both that they were required to file preliminary objections to the Declaration and that PennDOT had any ownership interest in Parcel 45.

Thereafter, the parties stipulated to certain matters and filed supplemental briefs.

It was in this supplemental briefing that the issue of whether the Pignettis used the Parcels “together for a unified purpose” came to the fore. PennDOT claimed that the Parcels were noncontiguous and that the Pignettis had not alleged that the Parcels were used together for a unified purpose as required by Section 705 of the Code. On PennDOT’s account, the Pignettis had waived their plottage claim.12 In response, the Pignettis insisted that they used the Parcels together for a unified purpose. The Pignettis explained that Mr. Pignetti owned an electrical business and that

10 26 Pa.C.S. § 705. 11 Whether PennDOT has an easement or any ownership interest at all in either parcel is disputed. The trial court found that PennDOT had no ownership interest. See T.C.O. at 3-4. 12 As the Commonwealth Court detailed, the lower court pleadings and proceedings were riddled with opportunities for the parties to raise, and the trial court to find, various waivers by both parties. See Pignetti, at *2-5. In sum, though, neither took advantage of these opportunities at the appropriate times. Because the trial court and the Commonwealth Court deemed the Section 705 issue to be sufficiently preserved and ripe, because none of the omissions implicated any court’s subject matter jurisdiction, and because neither party pursues a waiver argument before this Court, we, too, overlook these procedural anomalies.

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