Board of Supervisors v. Main Line Gardens, Inc.
155 A.3d 39
| Pa. | 2017Background
- Main Line Gardens and Coffman Associates (Main Line) were sued by Willistown Township for zoning violations arising from seven discrete 12‑day periods (84 days total); magisterial judgments entered against Main Line and appeals followed to common pleas.
- In common pleas the Township filed seven identical complaints alleging the same 84‑day period; arbitration produced one award for the Township and six defense judgments for Main Line (the parties and dockets complicated the res judicata arguments).
- Main Line moved for summary judgment in six cases arguing res judicata barred relitigation of damages decided in the arbitrated case; the Township sought leave to amend complaints to allege the original distinct 12‑day periods and filed cross‑motions invoking res judicata against Main Line.
- The trial court denied summary judgment motions, granted the Township leave to amend, then entered judgments for the Township in six cases; Main Line filed timely post‑trial motions asserting that res judicata/collateral estoppel were improperly rejected and that amendment was improper.
- The trial court sent an undocketed letter requesting briefs on post‑trial motions under a local rule; Main Line did not file additional briefs but had extensively briefed and argued the res judicata issues throughout earlier proceedings; the trial court denied post‑trial motions on the merits and later addressed res judicata in a Rule 1925 opinion.
- The Commonwealth Court dismissed Main Line’s appeals for failing to file briefs in support of post‑trial motions; the Pennsylvania Supreme Court reversed, holding Rule 227.1(b) does not require supporting briefs to preserve issues if the motion itself specifies grounds and the trial court rules on the merits.
Issues
| Issue | Main Line's Argument | Township's Argument | Held |
|---|---|---|---|
| Whether failure to file briefs in support of post‑trial motions waives issues for appeal under Pa.R.C.P. 227.1(b) | Briefs not required; post‑trial motions complied with Rule 227.1(b)(2) by specifying grounds and prior advocacy and preserved issues | Failure to brief post‑trial motions (per local rule/letter) constitutes waiver; DiSalle requires briefing to give trial court opportunity to decide | Held: Rule 227.1(b) does not mandate supporting briefs; issues preserved where motions specify grounds and trial court rules on merits; Commonwealth Court erred in dismissing appeals |
| Whether a trial court may order briefs and deem noncompliance waiver | If court orders briefs, noncompliance may justify waiver but only at the trial court’s discretion | Court orders should be enforced; failure to follow direction warrants waiver | Held: A trial court may request or order briefing and may, in its discretion, treat noncompliance as waiver, but Rule 227.1(b) itself does not impose a briefing requirement |
| Whether an appellate court may dismiss an appeal for lack of briefs when the trial court ruled on the merits | Appellate dismissal improper where trial court addressed issues on merits and parties extensively briefed earlier | Appellate courts may enforce procedural steps; briefs could have altered outcome and are required by precedent | Held: Appellate dismissal was improper where the trial court exercised discretion to rule on the merits and the record contained extensive prior briefing and argument on the issues |
Key Cases Cited
- Lane Enterprises, Inc. v. L.B. Foster Co., 710 A.2d 54 (Pa. 1998) (Rule 227.1 requires post‑trial motions to preserve issues for appeal)
- Chalkey v. Roush, 805 A.2d 491 (Pa. 2002) (post‑trial motions allow trial courts to correct errors and avoid appeals)
- Meyer, Darragh, Buckler, Bebenek & Eck, P.L.L.C. v. Law Firm of Malone Middleman, P.C., 137 A.3d 1247 (Pa. 2016) (standard of review for questions of law; plenary review)
- DiSalle v. P.G. Pub. Co., 544 A.2d 1345 (Pa. Super. 1988) (Superior Court held failure to brief an issue raised in post‑trial motion results in waiver — Court here finds that reasoning erroneous)
- Jackson v. Kassab, 812 A.2d 1233 (Pa. Super. 2002) (concurring opinion explains trial court’s authority to order briefing and that failure to comply may produce waiver)