C. Stedman v. Lancaster County Bd. of Commissioners
221 A.3d 747
Pa. Commw. Ct.2019Background
- Craig Stedman, Lancaster County District Attorney, filed an original-jurisdiction petition for review seeking declaratory and injunctive relief against the Lancaster County Board of Commissioners and individual commissioners, alleging they interfered with his exclusive control over forfeiture funds, human-resources decisions, and legal expense approvals.
- Stedman relied on the Forfeiture Act (42 Pa.C.S. §5803): cash/proceeds transferred to the county operating fund are to be placed in the county fund and then released for DA use; the county controller must perform an annual audit and report to the Attorney General, and the Attorney General must adopt public procedures and submit an annual report to legislative committees.
- Stedman used forfeiture funds to lease a vehicle after obtaining a controller certification; the Commissioners insisted Lancaster County contracting rules applied and investigated DA actions (including a personnel suspension), and later instructed the controller not to approve payment of legal expenses arising from Stedman’s suit.
- Stedman sought declarations that only the controller or Attorney General may audit forfeiture funds, that Commissioners may not review his employment decisions, and that appropriated funds must cover his legal fees; he named the Attorney General and controller as (non‑adverse) respondents.
- The Commissioners filed preliminary objections arguing Commonwealth Court lacks original jurisdiction because the Attorney General is not an indispensable party; the Commonwealth Court agreed, holding the Attorney General’s role under §5803 is ministerial/recipient only and thus not indispensable, and transferred the case to Lancaster County Court of Common Pleas.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Commonwealth Court has original jurisdiction under 42 Pa.C.S. §761(a)(1) because the Attorney General was named | Stedman: AG is an indispensable party whose statutory role will be affected by the requested declarations | Commissioners: AG is not indispensable; merely naming AG does not create original jurisdiction | Held: No original jurisdiction—AG not indispensable; preliminary objection sustained and matter transferred |
| Whether the Attorney General has authority under the Forfeiture Act to audit or investigate DA’s use of forfeiture funds | Stedman: §5803(k)/(j) implicates AG oversight and confidentiality duties, making AG’s role central | Commissioners: §5803(j) requires the county/controller to create the audit and submit it to AG; AG is a recipient with ministerial/reporting duties only | Held: AG lacks statutory authority to perform the audits/investigations alleged; AG is not an active auditing/enforcement party |
| Whether Lancaster County contracting rules apply to expenditures from forfeiture funds | Stedman: County contracting provisions do not apply to forfeiture expenditures under the Forfeiture Act | Commissioners: Lancaster Code procurement/contracting authority applies to county contracts and expenditures | Held: Merits not reached—court dismissed for lack of original jurisdiction and transferred case |
| Whether Commissioners may refuse to approve payment of DA's litigation costs and whether DA is entitled to those fees | Stedman: Separation-of-powers and prior appropriations entitle DA to payment of legal fees; Commissioners cannot retroactively defund | Commissioners: May withhold approval under county budget/approval processes | Held: Merits not reached—court declined to address due to lack of original jurisdiction and transferred case |
Key Cases Cited
- Pennsylvania School Boards Association, Inc. v. Commonwealth Association of School Administrators, Teamsters Local 502, 696 A.2d 859 (Pa. Cmwlth. 1997) (Commonwealth official not indispensable where statute gives no enforcement/administrative duties and dispute is local)
- Rachel Carson Trails Conservancy, Inc. v. Department of Conservation and Natural Resources of the Commonwealth, 201 A.3d 273 (Pa. Cmwlth. 2018) (indispensable-party inquiry focuses on whether relief can be granted without impairing party’s rights)
- Wagaman v. Attorney General of the Commonwealth of Pennsylvania, 872 A.2d 244 (Pa. Cmwlth. 2005) (to name AG indispensably, statute must vest AG with enforcement/administration duties over the subject)
- Dunbar v. Pennsylvania State Police, 902 A.2d 1002 (Pa. Cmwlth. 2006) (Commonwealth agency was indispensable where statute charged it with collection/maintenance and allowed challenges to records)
- Ballroom, LLC v. Commonwealth, 984 A.2d 582 (Pa. Cmwlth. 2009) (Commonwealth Court’s original jurisdiction requires an indispensable Commonwealth party)
- Commonwealth v. Locust Township, 968 A.2d 1263 (Pa. 2009) (subject‑matter jurisdiction is a pure question of law reviewed de novo)
- Perkasie Borough Authority v. Hilltown Township Water and Sewer Authority, 819 A.2d 597 (Pa. Cmwlth. 2003) (minimal or tangential involvement by a Commonwealth entity does not make it indispensable)