B.L. Yoder and J.I. Yoder, Wife and Husband, Individually and as Trustees of The Yoder Family Trust No. 2 and Hardwood Mill Trust v. Sugar Grove Area Sewer Authority
1927 C.D. 2016
| Pa. Commw. Ct. | Jan 5, 2018Background
- Barbara and Joseph Yoder (Owners), Old Order Amish, refuse use of electricity and operate an outhouse; their property abuts a sewer system subject to a municipal Mandatory Connection Ordinance requiring connection at owner’s expense.
- The Authority sought to compel connection; a 2013 trial-court order required Owners to connect but instructed the Authority to use the "least possible intrusion" on Owners’ religious convictions when choosing connection means.
- Owners objected to electricity powering a grinder pump and sought a preliminary injunction to prevent any electrically powered connection, asserting Religious Freedom Protection Act (RFPA), U.S. and Pa. constitutional claims.
- The trial court initially allowed the Authority discretion as to connection method but prohibited forcing Owners to open an electric account; this Court remanded, reinstating the 2013 instruction that the least intrusive means govern and directing the trial court to analyze preliminary-injunction factors using electricity use as the harm to be enjoined.
- On remand, the trial court found (1) Owners’ beliefs sincere and electricity use an irreparable harm, but (2) an electric grinder pump was the only feasible, tested means to connect to the Authority’s pressurized system and (3) granting an injunction would risk public health and operational problems from untested non-electric alternatives.
- The trial court denied the preliminary injunction; this Court affirmed, deferring to the trial court’s credibility and harms balancing, though a concurring judge dissented, arguing the RFPA places the burden on the Authority to prove least-restrictive means.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court disregarded its 2013 order recognizing Owners’ sincere religious belief against electricity | Yoder: Court ignored 2013 finding and compelled electricity use, undermining sincerity | Authority: 2013 order recognized beliefs but required connection; trial court properly weighed degree of harm given occasional electricity use | Court found the trial court did not disregard sincerity and reasonably weighed the moderate harm from electricity use against public health concerns |
| Whether the remand was misapplied by framing harm as lack of connection rather than electricity use | Yoder: Trial court compared different harms and reframed the issue | Authority: Trial court evaluated harm as electricity use vs. public/system harm; Owners’ all-or-nothing stance forced weighing against no-electricity consequences | Court held trial court complied with remand and properly weighed electricity harm against public health/operational harms |
| Who bears burden under RFPA to show least restrictive means | Yoder: RFPA places burden on Agency (Authority) to show least restrictive alternative; trial court improperly required Owners to propose non-electric options | Authority: Trial court considered evidence and Owners admitted electricity required; Authority presented evidence of least-intrusive means | Court agreed Authority bears burden on the merits but found Authority presented evidence and Owners did not refute it; court accepted trial court’s finding that electric grinder pump is least intrusive |
| Whether preliminary injunction should issue | Yoder: Requiring electricity forces abandonment of beliefs; Owners met injunction prerequisites | Authority: Granting injunction risks public health and would require untested/custom solutions | Court affirmed denial: Owners failed to show greater injury from denying injunction and failed to show injunction would not harm public interest; reasonable grounds supported trial court’s findings |
Key Cases Cited
- Reed v. Harrisburg City Council, 927 A.2d 698 (Pa. Cmwlth. 2007) (standard of appellate deference to trial-court injunction rulings)
- Unionville-Chadds Ford Sch. Dist. v. Rotteveel, 487 A.2d 109 (Pa. Cmwlth. 1985) (interference only where no reasonable grounds or law palpably misapplied)
- Summit Towne Ctr., Inc. v. Shoe Show of Rocky Mount, Inc., 828 A.2d 995 (Pa. 2003) (all preliminary-injunction prerequisites must be established)
- Cty. of Allegheny v. Commonwealth, 544 A.2d 1305 (Pa. 1988) (same; failure on any element defeats injunction)
- Brown v. City of Pittsburgh, 586 F.3d 263 (3d Cir. 2009) (discussion of RFPA and expanded protections for religious exercise)
- Rhoades v. School District of Abington Township, 226 A.2d 53 (Pa. 1967) (caution against constructions that unduly restrict religious freedom)
- Griffith v. United Air Lines, Inc., 203 A.2d 796 (Pa. 1964) (rejecting rigid rule application that yields unjust results)