West Middlesex Area School District Condemnation

46 Pa. D. & C.2d 687, 1969 Pa. Dist. & Cnty. Dec. LEXIS 155
CourtPennsylvania Court of Common Pleas, Mercer County
DecidedMay 7, 1969
Docketno. 22
StatusPublished

This text of 46 Pa. D. & C.2d 687 (West Middlesex Area School District Condemnation) 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
West Middlesex Area School District Condemnation, 46 Pa. D. & C.2d 687, 1969 Pa. Dist. & Cnty. Dec. LEXIS 155 (Pa. Super. Ct. 1969).

Opinion

Acker, J.,

The Borough of West Middlesex has filed a petition to strike off prelimi[688]*688nary objections of the property owners claiming that they do not state specifically the grounds relied upon by the condemnees, do not question the right of the condemnor to appropriate the condemned land, do not challenge the taking and are not in accordance with the Eminent Domain Code of June 22, 1964, P. L. 84, art. IV, §406, 26 PS §1-406, which authorizes the same.

The preliminary objections themselves are filed pursuant to the above mentioned statute claiming the action of the condemnor as being capricious, arbitrary, and an abuse of power. The property owners support this by allegations that the land is not taken for construction for school facilities “per se,” but rather to provide a second more costly and more dangerous and unnecessary access to a proposed parking lot for a proposed athletic field. However, it is contended that other land more direct and suitable for access was offered the condemnor free of charge by the Church of the Good Shepherd which is contiguous to the school, but that this offer was refused. Therefore, it is claimed that the taking will deprive the condemnees the means to provide for their necessities of life because the land involved is used for pasture and for pursuing crops, which will deny them the use and enjoyment of the balance of their land. And finally the condemnees claim that the proposed access road will create a serious safety problem to the public and students alike. Although the prayer as contained in the petition is that the declaration of taking be dismissed, the condemnees in their brief and at oral argument request a hearing upon these contested questions.

Considering first the “petition to strike off preliminary objection,” it is provided by the Eminent Domain Code of June 22, 1964, supra, that preliminary objections filed within 30 days of the condemnation are to be the exclusive method of challenging, “(1) [689]*689The power or right of the condemnor to appropriate the condemned property unless the same has been previously adjudicated.” Further, that failure to raise these matters by preliminary objection constitutes a waiver. It is required that the objections shall be specifically stated and that they must all be raised at one time. The court is obligated to determine promptly all preliminary objections and make such orders or decrees as justice shall require. “If an issue of fact is raised, the court shall take evidence by depositions or otherwise.”

The petition to strike on the basis that the preliminary objections do not specifically state the grounds relied upon is without merit as is the contention that the preliminary objections 'do not question the right of the condemnor to appropriate the condemned property. In the condemnee’s preliminary objection he specifically contends that the action is capricious, arbitrary and an abuse of power in that the land to be taken is for a more dangerous and unnecessary access when another access route is provided free of charge. It is recognized that the contention of hardship or inconvenience as contained in paragraph 2 of the preliminary objection is not a legally recognizable reason for denying the right of condemnation, but rather a proper element of damage: Borstnar v. Allegheny County, 332 Pa. 156, 2 A. 2d 715 (1958).

It is clear that the preliminary objections now constitute the sole and exclusive method of challenging condemnation proceedings under the Eminent Domain Code, supra: Mahan v. Lower Merion Township, 418 Pa. 558, 212 A. 2d 217 (1965); Faranda Appeal, 420 Pa. 295, 216 A. 2d 769 (1966); McConnell Appeal, 428 Pa. 270, 236 A. 2d 796 (1968).1

[690]*690“. . . a condemnation case involves two proceedings —the first to determine the propriety of the taking, the second to determine damages recoverable by the condemnee”: Valley Forge Golf Club v. Upper Merion Township, 422 Pa. 227, 230, 221 A. 2d 292 (1966).

Considering the condemnee’s petition in the nature of a demurrer to defendants’ factual averments as contained in their preliminary objections, the issue then becomes whether in order to arrive at a determination it is necessary to receive testimony either in court or by deposition as permitted by the rule. This in turn is dependent upon whether the property owners have alleged sufficient facts to present a question for determination as to the school authorities’ acts being capricious, arbitrary and an abuse of power. Narrowing the issue further, the property owners challenge the action of the school board in taking land for access to a proposed parking lot for a proposed athletic field which would be more costly, more dangerous and unnecessary where there is a more direct and suitable access which has been provided free of charge by a contiguous property owner.

It is recognized that once a condemnation is for public use and the condemnor has been properly delegated the power to condemn, the only area of judicial review of the actions of the condemnor is that of its administrative discretion. Generally, the amount or location of the land or type of estate condemned are not subject to judicial review unless such decisions are fraudulent, arbitrary or capricious: St. Peter’s Roman Catholic Parish v. Urban Redevelopment Authority of Pittsburgh, 394 Pa. 194, 146 A. 2d 724 (1958), cert. denied 359 U. S. 435 (1959); Faranda Appeal, supra; Hanni Appeal 420 Pa. 289, 216 A. 2d 774 (1966).

It appears that there has never been a case of a condemnor’s decision having been held fraudulent. Only [691]*691rarely has a condemnor’s action been held arbitrary or capricious: Winger v. Aires, 371 Pa. 242 (1962), school district condemned more land then it needed for “erecting ... an elementary school building”; Darlington and Wife v. The United States, 82 Pa. 382 (1876), condemnation of four sites for ultimate use of only one held unlawful; the American Oil Company v. School District of Philadelphia, 2 D. & C. 2d 525 (1954), school board desired to take site A to exchange for site B. Taking of land for .such an exchange was held unlawful: Pennsylvania Eminent Domain — Snitzer, sec. 406-2.3, p. 156.

This court views the discretion exercised in this case as somewhat similar to that which would be exercised by the Secretary of Highways in determining the location, width or length of a proposed highway. In Washington Park, Inc. Appeal, 425 Pa. 349, 353, 229 A. 2d 1, the court said:

“We have no power to substitute our discretion for his, nor to correct mistaken judgments. Furthermore, it is presumed that the highway department’s officials have performed their duties in good faith; the burden upon the appellant to prove the contrary, that the officials acted in a capricious or fraudulent manner, or that their actions were based upon .private motives inconsistent with the public welfare, is a heavy one.”2

The same rule is applicable to efforts to substitute the court’s discretion in place of the legislatively granted discretion of a redevelopment authority: Crawford v. Redevelopment Authority, 418 Pa. 549, 211 A. 2d 866 (1965). Discretion to exercise condemnation rights have been upheld, even though the land condemned could not be put to its contemplated use without securing a zoning change: Upper Dublin [692]*692Township Authority v. Piszek, 420 Pa. 536, 218 A.

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Related

Winger v. Aires
89 A.2d 521 (Supreme Court of Pennsylvania, 1952)
Upper Dublin Township Authority v. Piszek
218 A.2d 328 (Supreme Court of Pennsylvania, 1966)
Faranda Appeal
216 A.2d 769 (Supreme Court of Pennsylvania, 1966)
Hanni Appeal
216 A.2d 774 (Supreme Court of Pennsylvania, 1966)
Washington Park, Inc. Appeal
229 A.2d 1 (Supreme Court of Pennsylvania, 1967)
Crawford v. Redevelopment Authority
211 A.2d 866 (Supreme Court of Pennsylvania, 1965)
St. Peter's Roman Catholic Parish v. Urban Redevelopment Authority
146 A.2d 724 (Supreme Court of Pennsylvania, 1958)
McConnell Appeal
236 A.2d 796 (Supreme Court of Pennsylvania, 1968)
Borstnar v. Allegheny County
2 A.2d 715 (Supreme Court of Pennsylvania, 1938)
Darlington v. United States
82 Pa. 382 (Supreme Court of Pennsylvania, 1876)
Mahan v. Lower Merion Township
212 A.2d 217 (Supreme Court of Pennsylvania, 1965)
Valley Forge Golf Club v. Upper Merion Township
221 A.2d 292 (Supreme Court of Pennsylvania, 1966)

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Bluebook (online)
46 Pa. D. & C.2d 687, 1969 Pa. Dist. & Cnty. Dec. LEXIS 155, Counsel Stack Legal Research, https://law.counselstack.com/opinion/west-middlesex-area-school-district-condemnation-pactcomplmercer-1969.