Thornbury Twp. & Middletown Twp. v. County of Delaware & Delaware County Health Dept.

CourtCommonwealth Court of Pennsylvania
DecidedMay 6, 2025
Docket330, 603, 618 & 619 C.D. 2024
StatusPublished

This text of Thornbury Twp. & Middletown Twp. v. County of Delaware & Delaware County Health Dept. (Thornbury Twp. & Middletown Twp. v. County of Delaware & Delaware County Health Dept.) 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
Thornbury Twp. & Middletown Twp. v. County of Delaware & Delaware County Health Dept., (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Thornbury Township and : CASES CONSOLIDATED Middletown Township : : v. : No. 330 C.D. 2024 : Trial Court No.: CV-2022-009816 County of Delaware and : Delaware County Health Department : No. 603 C.D. 2024 : Trial Court No.: CV-2023-001002 County of Delaware and : Delaware County Health Department : No. 618 C.D. 2024 : Trial Court No.: CV-2023-000375 v. : : No. 619 C.D. 2024 Clifton Heights Borough, : Trial Court No.: CV-2023-000380 Eddystone Borough, Prospect : Park Borough, Ridley Park Borough, : Lower Chichester Township, and : Thornbury Township : County of Delaware and : Delaware County Health Department : : v. : : Clifton Heights Borough, : Eddystone Borough, Prospect : Park Borough, Ridley Park Borough, : Lower Chichester Township, and : Thornbury Township : : Clifton Heights Borough and : Eddystone Borough : : v. : : County of Delaware and Delaware : County Health Department : Appeal of: County of Delaware and : Delaware County Health Department : Argued: March 5, 2025

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE ANNE E. COVEY, Judge HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE LORI A. DUMAS, Judge HONORABLE STACY WALLACE, Judge HONORABLE MATTHEW S. WOLF, Judge

OPINION BY JUDGE COVEY FILED: May 6, 2025

The County of Delaware (County)1 and the County Health Department (DCHD) (collectively, Appellants) appeal from the Delaware County Common Pleas Court’s (trial court) February 28, 2024 order that permanently enjoined them from conducting any environmental health inspections and/or licensing of any food and beverage retail establishments, food stores, public and parochial schools, and public swimming pools located in Thornbury Township (Thornbury),2 Middletown Township (Middletown),3 Clifton Heights Borough (Clifton Heights), Eddystone Borough (Eddystone), Ridley Park Borough (Ridley Park), and Lower Chichester Township (Lower Chichester)4 (collectively, Appellees).5 Essentially, Appellants present one issue for this Court’s review: whether the trial court erred as a matter of law by concluding that Appellees satisfied the requirements for a permanent injunction.6 After review, this Court affirms.

1 The County is a Second Class County governed by a Home Rule Charter adopted in 1975. 2 Thornbury is a Second Class Township. 3 Middletown is a Second Class Township. 4 Lower Chichester is a First Class Township. 5 Prospect Park Borough is no longer a party to this matter. 6 Appellants present three issues in their Statement of Questions Involved: whether the trial court erred as a matter of law by concluding that: (1) Appellees are exempt from DCHD’s

2 Background On February 28, 2022, the Commonwealth of Pennsylvania (Commonwealth), Department of Health (DOH) certified DCHD as a county health department authorized to assume responsibility for conducting the inspections outlined in the Local Health Administration Law (Law/Act 315),7 specifically, routine and complaint-based environmental health inspections for various facilities including food facilities, food trucks, private wells and on-site septic systems, campgrounds, organized camps, mobile home parks, public bathing places/pools, and institutions including nursing homes and daycare centers. See Reproduced Record (R.R.) at 567a-568a. On March 3, 2022, the County notified all 49 of its municipalities that DCHD would begin exercising its powers on April 2, 2022. See R.R. at 117a, 119a- 120a. Appellants also enacted DCHD Rules and Regulations (DCHD’s Regulations). Section 100.3 of DCHD’s Regulations proclaims:

jurisdiction; (2) Appellees satisfied the elements necessary for a permanent injunction against Appellants; and (3) Appellants failed to satisfy the elements necessary for a permanent injunction against Appellees. See Appellants’ Br. at 5. On April 11, 2024, Appellees filed a Motion to Quash Appellants’ appeal in this Court on the basis that Appellants failed to file a post-trial motion in the trial court. Appellants opposed the Motion to Quash, arguing that because their appeal was filed pursuant to Pennsylvania Rule of Appellate Procedure (Rule) 311(a)(4) (interlocutory appeals as of right), post-trial motions were not required. On June 12, 2024, this Court denied the Motion to Quash, stating that post-trial motions are unnecessary where, as here, the appeal is interlocutory. Lower Chichester argues that since the declaratory judgment portion of the trial court’s February 28, 2024 order is not immediately appealable under Rule 311(a)(4), this Court lacks jurisdiction to review that issue. This Court agrees. While Rule 311(a)(4) permits an immediate appeal from the trial court’s order granting the injunction, it does not also give this Court jurisdiction over the declaratory judgment portion of that order. Because Appellants represented in opposition to Appellees’ Motion to Quash that this appeal was interlocutory, and this Court denied the quashal on that basis, the only matter before this Court is whether the trial court erred by granting the permanent injunction in Appellees’ favor. This Court has restated Appellants’ issues accordingly. 7 Act of August 24, 1951, P.L. 1304, as amended, 16 P.S. §§ 12001-12030.

3 No city, township, borough, or other municipality located within [the] County, except those municipalities which are exempt from the jurisdiction of [DCHD] by Section 14 of the [Law, 16 P.S. § 12014,] shall adopt any rule, regulation, standard, or procedure not in conformity with [DCHD’s Regulations], and any such rule, regulation, standard, or procedure presently in existence shall be superseded to the extent that it is inconsistent with [DCHD’s Regulations].

R.R. at 847a; see also R.R. at 653a. By March 17, 2022 letter, Thornbury notified Appellants that it was exempt from DCHD’s jurisdiction and asked DCHD to “refrain from any further communication with its residents, restaurants[,] and businesses within [Thornbury] to avoid unnecessary confusion.” R.R. at 42a. By April 1, 2022 letter, Lower Chichester also notified Appellants that it was exempt from DCHD’s jurisdiction. See R.R. at 1558a. On April 2, 2022, DCHD began exercising its powers and duties under the Law and, when attempting to conduct inspections in certain areas of Appellees’ jurisdiction, DCHD experienced confrontation or was not permitted in facilities to conduct inspections. By April 4, 2022 letter, Appellants informed Lower Chichester that they disagreed with its interpretation of the Law. See R.R. at 1560a. By April 8, 2022 letter, Lower Chichester sought guidance from DOH on how to proceed given Appellants’ rigid position that Lower Chichester must relent to DCHD. 8 See

8 Lower Chichester stated in the April 8, 2022 letter: There are certainly functions that a County health department could perform that would benefit [Lower Chichester] residents and businesses. But why is this being presented as a hostile takeover rather than a cooperative effort? Why can’t both [Lower Chichester] and the County provide discrete areas of health services to [Lower Chichester] residents and businesses? Why is [Lower Chichester’s] only option to surrender and abandon is Board of Health? R.R. at 1562a. 4 R.R. at 1561a-1562a. By April 19, 2022 letter, DOH’s acting Secretary directed the municipalities to amicably work together to provide services to the community.9 See R.R. at 1563a-1564a. By June 1, 2022 letter to DOH and Appellants, Lower Chichester requested a meeting to discuss their differing interpretations of the Law. See R.R. at 1575a-1576a. Although Appellants responded and asked Lower Chichester to “stay tuned,” no meeting ever took place. R.R. at 776a, 1546a.

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Bluebook (online)
Thornbury Twp. & Middletown Twp. v. County of Delaware & Delaware County Health Dept., Counsel Stack Legal Research, https://law.counselstack.com/opinion/thornbury-twp-middletown-twp-v-county-of-delaware-delaware-county-pacommwct-2025.