Southland Corp. v. Zoning Hearing Board

36 Pa. D. & C.3d 59, 1985 Pa. Dist. & Cnty. Dec. LEXIS 337
CourtPennsylvania Court of Common Pleas, Bucks County
DecidedJune 10, 1985
Docketno. 84-4598-13-5
StatusPublished
Cited by1 cases

This text of 36 Pa. D. & C.3d 59 (Southland Corp. v. Zoning Hearing Board) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Bucks County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Southland Corp. v. Zoning Hearing Board, 36 Pa. D. & C.3d 59, 1985 Pa. Dist. & Cnty. Dec. LEXIS 337 (Pa. Super. Ct. 1985).

Opinion

GARB, P.J.,

These are two separate appeals from the decision (deemed decision) of the Zoning Hearing Board of Warrington Township. As a result of this deemed decision, the application of The Southland Corporation for both a use and dimensional variance was granted. Southland is the equitable owner of a portion of the tract in question and took this appeal primarily for the purpose of protecting its rights. Warrington Township and Ran[60]*60dolph Scott, Esq., took these appeals from the effect of the deemed decision of the board. All appeals were timely filed. By our order herein, we will consolidate these matters for decision. Both cases were argued before the undersigned.

The property in question consists of approximately 9.5 acres of undeveloped land located at the southeast corner of the intersection of Shetland Drive and Route 611 with 395 feet of frontage on Route 611 and 850 feet frontage on Shetland Drive. The premises involved in the subject application, however, is the corner of the above described property and is approximately 230 feet in frontage along Route 611 and 225 feet on Shetland Drive consisting of slightly over one acre. Essentially, the application likewise consists in a subdivision although there is no evidence to reveal that any subdivision of the property has ever been approved. The application is for a use variance to permit the construction and operation of a Seven-Eleven food store with gasoline pumps and also a-dimensional variance to permit this use on the slightly over one acre of land.

Hearings were held before the board on April 16, 1984, May 2, 1984 and May 21, 1984,. at which time, the board chairman orally announced the decision of the board as a denial of the application. However, the record was clearly closed on'May 2, 1984. The hearing on May 21, 1984 was scheduled specifically and solely for the purpose of the announcement of the board decision. The written decision of the board with its findings of fact and conclusion of law was entered on June 22, 1984, more than 45 days after the last hearing before the board. Therefore, under and pursuant to the provisions of section 908(9) of the Municipalities Planning Code, the Act of July 13, 1979, P.L. 105, 43 §1, 53 P.S. §10908, the relief sought by the applicant, South-[61]*61land Corporation, is “deemed approved”. These appeals from that “deemed approval” were timely filed.

. There are two procedural questions which must be addressed first. The first of these is whether a “deemed approval” is appealable. We believe that question is easily answered in the affirmative. In relevant part, section'908(9) provides as follows:

“ . . . When a decision has been rendered in favor of the applicant because of the failure of-the Board to meet or render a decision as hereinabove provided, (45 days after the last hearing before the Board) the municipality shall give public notice of said decision within 10 days in the same manner as provided in §(.l) of this Section. Nothing in this subsection shall prejudice the right of any party opposing the application to urge that such a decision is erroneous.” (Emphasis supplied)

We believe that this language clearly reflects the intention of the legislature that a “deemed approval” by a zoning hearing board is an appealable order available to any party opposing the original application. See Foltz, Jr. v. Monroeville and Borden, 5 Pa. Commw. 304, 290 A.2d 269 (1972) and Upper Allen Township v. Zoning Hearing Board, 77 Pa. Commw. 582, 466 A.2d 292 (1983).

Having established that the matter is properly and appropriately before us, the second procedural question is with regard to our scope of review. We have found no law deciding this question. South-land argues that our scope of review is an extremely narrow one to determine only whether the record reflects that there has been a “deemed approval”. Once that is determined, Southland argues that we may go no further in reviewing the essence of that decision in terms of the merits of the application itself as established on the record. With this we can[62]*62not agree. The effect of such a narrow scope of review would give rise to serious constitutional concerns in terms of procedural due process, by virtue of the delegation of practically unlimited powers to the zoning hearing board as a quasi legislative body, under these circumstances, .to determine the permissible uses of property regardless of the specific provisions of the zoning ordinance, merely by inaction, without the preservation of any rights of review of any other parties who have standing in the matter. If such were the case, a zoning hearing board need never act whenever it determines to grant the relief applied for, secure in the belief that its decision can never be overturned. The resulting anomalous conclusion is obvious. If the board enters its decision in appropriaté form in writing 45 days after the last hearing granting the relief, all aggrieved parties have standing and would have the opportunity to appeal that decision and test its merits in a court of law. However, by -waiting until the 46th day, the zoning hearing board would be able to cut off such rights of review. It is inconceivable to us that the legislature could have contemplated or intended such a result.

The obvious purpose of the “deemed approval” provisions of the Municipalities Planning Code was to compel zoning hearing boards to act in a timely manner so that the rights of property owners not be prejudiced by delay.

“Thus, the sanction of deemed approval is aimed at accelerating the deliberation process and improving the quality of decisions reached by municipal officials. We think those goals have been served by the deemed approval of appellant’s preliminary plan in the instant case. We cannot, however, accept appellant’s argument that section 508 was also intended to prevent aggrieved protestants from pursuing [63]*63their appeal rights under section 1007 of the MPC. As stated by the Court of Common Pleas:

‘It would'be an anomalous result, indeed, for the legitimate interests of aggrieved land owners to go unnoticed through no fault of their own but rather through the township’s mistake. The legislature did not intend that the rights of these aggrieved land owners be sacrificed in the zeal to punish offending townships under Section 508 of MPC.’ ” Upper Allen Township v. Zoning Hearing Board, supra.

The purpose, therefore, of the “deemed approved” provisions is obvious. See Humble Oil and Refining Company v. East Lansdowne Borough, 424 Pa. 309, 227 A.2d 664 (1967). We do not believe that it was ever intended by the legislature to give the applicant a windfall in the form of protection from review of the merits of the application, merely because the zoning hearing board was dilatory.

Having decided that we must reach the merits of the “decision” of the zoning hearing board, the scope of review question remains unanswered. We have before us a full record made before the zoning hearing board.

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Bluebook (online)
36 Pa. D. & C.3d 59, 1985 Pa. Dist. & Cnty. Dec. LEXIS 337, Counsel Stack Legal Research, https://law.counselstack.com/opinion/southland-corp-v-zoning-hearing-board-pactcomplbucks-1985.