Z&R Cab, LLC v. Philadelphia Parking Authority

CourtCommonwealth Court of Pennsylvania
DecidedApril 22, 2025
Docket1582 C.D. 2022
StatusPublished

This text of Z&R Cab, LLC v. Philadelphia Parking Authority (Z&R Cab, LLC v. Philadelphia Parking Authority) 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
Z&R Cab, LLC v. Philadelphia Parking Authority, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Z&R Cab, LLC, Zoro, Inc., : Ronald Blount, and Debra Bell, : Appellants : : v. : No. 1582 C.D. 2022 : Philadelphia Parking Authority : Argued: March 4, 2025

BEFORE: HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE MARY HANNAH LEAVITT, Senior Judge

OPINION BY JUDGE McCULLOUGH FILED: April 22, 2025

Z&R Cab, LLC, Zoro, Inc., Ronald Blount, and Debra Bell (collectively, Licensees) appeal from the October 27, 2022 judgment of the Court of Common Pleas of Philadelphia County (trial court) entered upon the jury verdict in favor of the Philadelphia Parking Authority (Authority) and against Licensees, and from the trial court’s July 16, 2020 order granting the Authority’s motion for partial summary judgment. After careful review, we affirm. I. Factual and Procedural Background Licensees are two Philadelphia taxi companies, a former Philadelphia taxi driver, and the assignee of a Philadelphia taxi dispatch company. Prior to 1990, the Pennsylvania Public Utility Commission (PUC) regulated all taxicabs and limousines in the Commonwealth of Pennsylvania, including those in Philadelphia, subject to the provisions of the Public Utility Code (Code).1 In 1990, the General Assembly passed the Medallion Act, which required the PUC to regulate Philadelphia taxicabs pursuant to distinct provisions not applicable to any other public utilities in Pennsylvania. 66 Pa.C.S. § 2414. In 2004, the General Assembly enacted Act 94,2 transferring the regulatory responsibility for the Philadelphia taxicab and limousine industries from the PUC to the Authority. Act 94 also created a budget submission process for the Authority to follow and it prescribed a formula that the Authority must use to ascertain assessments imposed on Philadelphia taxi cabs. Pursuant to Section 5707(b) of Act 94, the Authority, through its Taxicab and Limousine Division (TLD), established budget and fee schedules under which it assessed regulatory fees on the various participants in the Philadelphia taxicab and limousine industries. The Authority would submit the budget and fee schedule to the Appropriations Committees of the Pennsylvania Senate and House of Representatives each year. Unless the Appropriations Committees adopted a disapproval resolution by April 15, the Authority’s budget and fee schedule would become effective. Taxicab and limousine industry members were required to pay these fees in order to maintain their certificates of public convenience and/or their ability to operate in the Philadelphia taxicab and/or limousine industries. Failure to pay the fees also could result in the Authority’s imposition of fines and penalties on industry members. Certain taxicab operators refused to pay regulatory assessments and fees

1 66 Pa.C.S. §§ 101-3316.

2 Act of December 30, 2002, P.L. 2001, No. 230, reenacted and amended by the Act of July 16, 2004, P.L. 758, No. 94, as amended, 53 Pa.C.S. §§ 5701-45.

2 imposed by the Authority and filed a petition in this Court’s original jurisdiction, challenging the constitutionality of Section 5707 of Act 94. In MCT Transportation Inc. v. Philadelphia Parking Authority, 60 A.3d 899 (Pa. Cmwlth.), aff’d, 81 A.3d 813 and 83 A.3d 85 (Pa. 2013), this Court found in favor of the taxicab operators, concluding that Section 5707 of Act 94 was unconstitutional because it violated the Pennsylvania Constitution by impermissibly delegating legislative power to the Authority by granting the Authority the power to formulate its own budget and fee schedule without restriction or guidance from the General Assembly. We found that the Appropriations Committee’s power to disapprove of the Authority’s budget did not suffice to pass constitutional muster under the non-delegation doctrine. We also found that Section 5707 of Act 94 deprived the taxicab operators of due process because it did not provide any procedure for challenging the Authority’s fee schedule, either before or after its adoption. Id. at 916- 17. Our decision was later upheld by the Pennsylvania Supreme Court. In response to MCT Transportation, in July 2013, the General Assembly enacted Act 643 to amend Act 94 to cure the constitutional shortcomings. Act 64 established a new process for setting the Authority’s budget and fee schedule and for calculating the individual taxicab assessment. By enacting Act 64, the General Assembly amended Section 5707 and added Sections 5707.1 and 5710. Section 5707 of Act 64 now requires legislative approval of the Authority’s proposed budgets. Regarding assessments for taxicabs, limousines, and dispatchers, in Section 5707(c)(1)(v), the General Assembly set the taxicab assessment for the fiscal years ending June 30, 2013, and June 30, 2014, to be $1,250.00. 53 Pa.C.S. § 5707(c)(1)(v). Section 5707.1(a) requires the Authority to serve notice of

3 Act of July 9, 2013, P.L. 455, No. 64, as amended, 53 Pa.C.S. §§ 5707.1, 5710.

3 assessment to each regulated party. 53 Pa.C.S. § 5707.1(a). Section 5707.1(b) permits regulated parties to file a petition with the Authority that avers that the assessment is excessive or otherwise invalid. 53 Pa.C.S. § 5707.1(b). On October 22, 2013, Licensees filed a civil rights class action in the United States District Court for the Eastern District of Pennsylvania under 42 U.S.C. § 1983, alleging a federal due process violation and seeking a full refund of the fees they had paid. The District Court dismissed the case on the ground that it lacked subject matter jurisdiction. Licensees appealed the decision to the Third Circuit Court of Appeals. The Circuit Court of Appeals reversed the decision and remanded the case on the ground that the District Court had subject matter jurisdiction because Licensees’ claim arose under the United States Constitution and federal law. Z&R Cab, LLC v. Philadelphia Parking Authority, 616 F. App’x 527 (3d Cir. 2015). Upon remand, the District Court deferred to a state court. On June 10, 2014, Licensees filed a complaint in the trial court to pursue remedies under 42 U.S.C. § 1983, claiming that all the putative class members are entitled to a full refund of all fees that they paid from 2004 through 2013 (the period when the now-declared unconstitutional Act 94 was in effect). The Authority filed a motion for summary judgment asking the trial court to rule that the putative class members are not entitled to a class-wide refund. The trial court granted the motion on the ground that MCT Transportation did not hold that the assessments and fees that Licensees paid to the Authority were beyond the Authority’s power. The trial court further noted that MCT Transportation held that the Authority denied Licensees the procedural due process right to challenge assessments. The trial court ordered the Authority to provide a review procedure regarding assessments and the fees that it charged the taxicab industry from 2004 to

4 2013 under Act 94. The trial court ruled, inter alia, that the Authority shall issue notices of assessment to the members of the taxicab industry to whom it charged fees in the years 2004-2013. Licensees appealed the decision to this Court, which reversed and remanded the case. Z&R Cab, LLC v. Philadelphia Parking Authority, 187 A.3d 1025 (Pa. Cmwlth. 2018) (en banc).

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Z&R Cab, LLC v. Philadelphia Parking Authority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/zr-cab-llc-v-philadelphia-parking-authority-pacommwct-2025.