Ruth A.M.E. Zion Church v. Redevelopment Authority

71 Pa. D. & C.2d 104, 1975 Pa. Dist. & Cnty. Dec. LEXIS 403
CourtPennsylvania Court of Common Pleas, Mercer County
DecidedDecember 17, 1975
Docketno. 620, C.D. 1975
StatusPublished

This text of 71 Pa. D. & C.2d 104 (Ruth A.M.E. Zion Church v. Redevelopment Authority) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Mercer County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ruth A.M.E. Zion Church v. Redevelopment Authority, 71 Pa. D. & C.2d 104, 1975 Pa. Dist. & Cnty. Dec. LEXIS 403 (Pa. Super. Ct. 1975).

Opinion

STRANAHAN, P. J.,

The matter before the court is the disposition of preliminary objections filed by both the Redevelopment Authority of Sharon (hereinafter the “Authority”) and the Commonwealth of Pennsylvania, Department of Transportation, (hereinafter “PennDot”) to a petition for viewers filed by the Ruth African Methodist Episcopal Zion Church (hereinafter “Zion Church”).

Zion Church is a nonprofit religious corporation and the owner in fee simple of certain property on the southwest corner of Ohio Street and Sterling Avenue in Sharon on which is erected a church and parsonage. This property is within the project boundaries of the South Flats Project, which is an urban redevelopment and renewal project of the Authority.

As part of this project, the Authority and PennDot executed an agreement on March 15, 1973, in which the latter agreed to construct, by contract or otherwise, and at its own expense, Legislative Route 43142, section AOl from station 0+16. to station 12+62. .More specifically, this part of the [106]*106project involved the widening, improvement, paving and relocation of a portion of Ohio Street.

The agreement also provided that the Authority, at its own cost and expense, would obtain, by eminent domain or otherwise, the fee simple title to all land upon which the relocated portion of Ohio Street was to be constructed and would convey this land to PennDot. It further provided that construction would be in accordance with plans and specifications prepared or approved by PennDot and that PennDot would be reimbursed by the Authority for actual costs incurred in the construction of gutters, curbs, sidewalks and parking lot approaches. The agreement also contained provisions concerning removal of buildings and debris, fencing, relocation of utilities and road maintenance following completion of construction.

With respect to the property owned by Zion Church, the deed executed on March 19, 1974, between the Authority and PennDot shows that that property abutted on a portion of the property conveyed to PennDot for purposes of reconstructing Ohio Street. In its petition, Zion Church claimed its property had incurred consequential damages and alleged:

“9. As a result of the raise in grade of Ohio Street in front of the property of condemnee, occasioned entirely by the reconstruction of Ohio Street by the Department of Transportation in the furtherence of the Urban Renewal project of the Redevelopment Authority, the property of the condemnee has been severly damaged, the utility of the church building and parsonage has been partially destroyed, the access to the property and buildings has been restricted and severly damaged, a drainage prob[107]*107lem has been created and the property of the condemnee has been otherwise damaged.”

Moreover, in its petition, Zion Church named both the Authority and PennDot as “condemnors” liable for the alleged consequential damages.

Both the Authority and PennDot filed preliminary objections to this petition and, pursuant to a petition by the latter, an evidentiary hearing was held.

The first question raised is whether the petition filed and evidence adduced at the hearing are sufficient to state a claim for consequential damages under section 1-612 of the Eminent Domain Code.

The disposition of preliminary objections to petitions for the appointment of viewers by property owners alleging de facto takings or compensable injuries was decided in Jacobs v. Nether Providence Twp., 6 Pa. Commonwealth Ct. 594, 297 A.2d 550 (1972). The court held that preliminary objections testing the sufficiency of such petition should be sustained if, as a matter of law, such a petition, even if taken as true, is insufficient to establish a de facto taking or compensable injury. Additionally, the court held that where the averments of the petition are of such a nature that they may make out the cause of action, if proven, the trial court should resolve that issue before granting petition for viewers.

A number of considerations compel us to conclude that the petition and evidence presented at the hearing were sufficient to state a claim. First, the petition is drafted substantially in the language of section 1-612. Second, both the original and revised plans introduced into evidence by PennDot •indicate that a change in grade in Ohio Street was [108]*108planned throughout the course of the project. Finally, and perhaps most importantly, the uncontradicted testimony of Richard E. Williams, the resident engineer for PennDot in this project, shows that defendants were aware of such potential damage because a number of meetings were held with representatives of Zion Church to discuss the problems attendant to the Ohio Street project and possible solutions thereto.

Parenthetically, it should be noted that the fact that Zion Church failed to introduce any of this evidence is immaterial. The fact is that the evidence presented by defendant is probative of the very facts which Zion Church had to prove to make out a cause of action for consequential damages.

As such, it is determined that the petition avers and the evidence advanced at the hearing establish a claim under section 1-612 of the Eminent Domain Code of June 22, 1964, (Sp. Sess.) P. L. 84, 26 PS 81-612.

The second and more difficult question raised is which of the defendants is hable as the condemnor for any alleged consequential damages incurred by Zion Church as a result of the Ohio Street construction project.

In resolving this question, the court is guided by the following definitions from section 1-201 of the Eminent Domain Code:

“(1) ‘Condemn’ means to take, injure or destroy private property by authority of law for a public purpose.
a
“(3) ‘Condemnor’ means the acquiring agency, including the Commonwealth of Pennsylvania, taking, injuring or destroying private property under authority of law for a public purpose.
[109]*109“(5) ‘Acquiring agency’ means any entity vested with the power of eminent domain by the laws of the Commonwealth, including the Commonwealth.”

The positions of defendants are clear. PennDot maintains that the agreement between it and the Authority renders the latter the acquiring agency and thus the condemnor. As such, it concludes that the Authority is liable for any consequential damages arising out of the project.

PennDot further contends that it is acting only in a private contractor capacity in the instant case and that it should not be exposed to condemnor liability when acting in such a capacity as a matter of public policy. It argues that if it is held liable for consequential damages in such circumstances, it will be unable in the future to extend contracting services to local government units.

The Authority, on the other hand, argues that the obligations of the Authority with respect to the Ohio Street project axe set foxth in the agxeement and that there is no provision imposing liability for consequential damages on it. It contends that the agreement does nothing to change the situation which would exist if PennDot had acquired the right-of-way itself.

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Related

Jacobs v. Nether Providence Township
297 A.2d 550 (Commonwealth Court of Pennsylvania, 1972)

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Bluebook (online)
71 Pa. D. & C.2d 104, 1975 Pa. Dist. & Cnty. Dec. LEXIS 403, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ruth-ame-zion-church-v-redevelopment-authority-pactcomplmercer-1975.