INTERNATIONAL DEVELOPMENT CORP. v. Davidge
26 A.3d 1234
| Pa. Commw. Ct. | 2011Background
- International filed a quiet-title action to determine ownership of oil, gas and mineral rights beneath land owned by the Pennsylvania Game Commission in Wyoming County.
- The trial court dismissed International's amended complaint, holding the Board of Property had exclusive jurisdiction because the Commonwealth asserted an interest in the mineral estate.
- Deeds show the 1921 conveyance to the Game Commission reserved all oil, gas and other minerals to the grantor’s heirs and assignees, excluding them from the gaming surface grant.
- The Trust acquired the assets of United States Leather Company, which had previously owned the mineral rights, and now claims mineral-title ownership.
- The Game Commission asserts surface ownership and that its 1921 deed preserved mineral rights; it also argues potential ownership by adverse possession or unclaimed-property administration.
- The Treasury Department intervened, arguing it may own or administer the mineral rights under the Unclaimed Property Act if the mineral estate is abandoned or unclaimed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Board of Property has exclusive jurisdiction over mineral-title disputes. | International: Board exclusive due to Commonwealth interest. | Game Commission: Board has exclusive jurisdiction since land is Commonwealth land and minerals are disputed. | Yes; Board of Property has exclusive jurisdiction. |
| Whether a quiet-title action is proper to adjudicate mineral ownership against Commonwealth interests. | International argues private-party title dispute; Commonwealth need not be sued. | Game Commission asserts title; quiet-title is proper to resolve mineral ownership. | Quiet-title action is the appropriate vehicle under exclusive Board jurisdiction. |
| Whether Bannard controls, limiting Commonwealth involvement to a non-definitive role. | Bannard shows intervention by Commonwealth does not divest jurisdiction. | Bannard distinguished; here the Commonwealth claims title to the mineral estate. | Bannard distinguished; the present dispute involves disputed Commonwealth title. |
| Whether other cases cited align with the Board's exclusive jurisdiction over mineral estates. | Moore, Kister, Krulac, etc., support private-party adjudication. | Those cases involved disputes affecting Commonwealth title; distinguishable. | Distinguishable; Board jurisdiction applies here. |
| Whether the matter should be remanded to transfer to the Board of Property. | Remand not necessary if trial court lacked jurisdiction. | Court should transfer record to Board per Judicial Code §5103. | Remand to transfer record to Board of Property. |
Key Cases Cited
- Bannard v. New York State Nat. Gas Corp., 404 Pa. 269 (Pa. 1961) (intervention not divesting court of jurisdiction where Commonwealth title contested)
- Moore v. Department of Environmental Resources, 129 Pa.Cmwlth. 628 (Pa. Cmwlth. 1989) (reversal of Board order in mineral-ownership dispute)
- Kister v. Pennsylvania Fish Commission, 77 Pa.Cmwlth. 430 (Pa. Cmwlth. 1983) (Board jurisdiction over surface/mineral interest in condemnation context)
- Krulac v. Pennsylvania Game Commission, 702 A.2d 621 (Pa.Cmwlth.1997) (Board has exclusive jurisdiction over ejectment vs. trespass damages)
- Delaware Avenue, LLC v. Department of Conservation and Natural Resources, 997 A.2d 1231 (Pa.Cmwlth.2010) (Board exclusive for title to newly formed land claimed by private and Commonwealth)
- Stair v. Pennsylvania Game Commission, 28 Pa.Cmwlth. 457 (Pa.Cmwlth. 1977) (Board jurisdiction over culm banks on Game Commission land)