Adams Twp. v. Richland Apl of: Richland, 154 A.3d 250

Adams and Richland Townships in Cambria County disputed their common boundary; Adams was formed from Richland in 1870 but the original description is lost.
County tax assessment maps long depicted a boundary line used by residents; two surveyors (Brown for Adams, Kalina for Richland) proposed different original lines based on historical and monument evidence.
A board of commissioners appointed under the Second Class Township Code held hearings, found the record insufficient to locate the 1870 boundary, rejected both experts, but found substantial, reliance-driven improvements by property owners based on the tax map line.
The Board recommended adopting the tax assessment line as the municipal boundary to protect those who had reasonably relied on it; the trial court confirmed that report and entered an order accordingly.
The Commonwealth Court vacated and remanded, holding the Board must first ascertain the original boundary before considering acquiescence; Richland appealed to the Pennsylvania Supreme Court.
The Supreme Court reversed the Commonwealth Court, holding that when commissioners cannot ascertain the original boundary, they may apply the equitable doctrine of acquiescence and adopt an alternative line supported by substantial, reliance-induced improvements.

Issue	Plaintiff's Argument (Adams)	Defendant's Argument (Richland)	Held
Whether commissioners may adopt an alternative boundary based on acquiescence when the original line cannot be located	Board must locate original 1870 boundary; adopting an alternative to suit convenience is unauthorized	If original cannot be ascertained, commissioners may adopt an alternative (tax map) under acquiescence to avoid continued disruption	Held: Yes. If commissioners cannot conclusively locate the original boundary, they may consider acquiescence and adopt an alternative line supported by evidence of reliance
Whether commissioners erred by considering acquiescence before establishing the original boundary	Consideration of acquiescence is premature; original boundary must be found first	Acquiescence may be considered once the board determines the original line cannot be established	Held: Rejected. Board need not postpone consideration of acquiescence where it has concluded the original boundary cannot be determined
Whether evidence of substantial improvements and induced reliance was sufficient to apply acquiescence	Testimony of two owners lacked monetary proof; only one owner (Burnworth) showed substantial improvements	Board reasonably found three owners built homes or made large renovations in reliance on the tax map line; monetary proof not required	Held: Sufficient. Construction of homes and renovations constitute substantial improvements induced by municipal acquiescence

Laflin Borough v. Yatesville Borough, 404 A.2d 717 (Pa. Cmwlth. 1979) (distinguishes boundary disputes from boundary changes and upholds judicial resolution of disputed lines)
Laflin Borough v. Jenkins Township, 422 A.2d 1186 (Pa. Cmwlth. 1980) (discusses limits of estoppel/acquiescence absent substantial improvements)
Moon Township v. Findlay Township, 553 A.2d 500 (Pa. Cmwlth. 1989) (recognizes acquiescence doctrine may apply in true boundary disputes but requires substantial, reliance-induced improvements)
In re Viola, 838 A.2d 21 (Pa. Cmwlth. 2003) (applies acquiescence analysis and underscores need for improvements on the subject property)
Collier Township v. Robinson Township, 360 A.2d 841 (Pa. Cmwlth. 1976) (holds legislature’s failure to enact uniform boundary-change statute invalidated preexisting statutory procedures for boundary changes)
Robinson Township v. Collier Township, 303 A.2d 575 (Pa. Cmwlth. 1973) (treats board of commissioners’ report as having force and effect of jury verdict)
Michigan v. Wisconsin, 270 U.S. 295 (U.S. 1926) (acknowledges long acquiescence as conclusive in disputes between sovereigns)