Meyer v. Community College of Beaver County
625 Pa. 563
| Pa. | 2014Background
- CCBC is a Pennsylvania political subdivision that offers post-secondary education for tuition and fees.
- Former CCBC students allege they enrolled in and completed substantial work in CCBC’s police training program before it was decertified in 2002.
- Plaintiffs sue under UTPCPL for unfair trade practices by a “person.”
- CCBC argued UTPCPL defines “person” to include only private entities, excluding political subdivisions; also argued Tort Claims Act immunity from statutory liability.
- Commonwealth Court previously held UTPCPL ambiguity and remanded; the Supreme Court granted review limited to the “person” definition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether UTPCPL’s “person” includes political subdivision agencies. | CCBC reads “any other legal entities” as including political subdivisions. | Statutory language excludes government agencies; common-law presumptions and public policy counsels against inclusion. | Ambiguous; Court held not to include political subdivisions; reversed Commonwealth Court on this issue. |
Key Cases Cited
- Meyer v. Community College of Beaver County, 30 A.3d 587 (Pa.Cmwlth.2011) (rejected inclusion of governmental agencies under UTPCPL post-decision (en banc))
- Northampton Cty. Area Cmty. College v. Dow Chemical, 566 A.2d 591 (Pa. Super. Ct. 1989) (sovereign immunity and related principles invoked in statutory interpretation)
- Dechert LLP v. Commonwealth, 998 A.2d 575 (Pa. 2010) (statutory interpretation standard and plenary review)
- St. Elizabeth’s Child Care Ctr. v. Dep’t of Pub. Welfare, 963 A.2d 1274 (Pa. 2009) (canon of expressio unius and related interpretive rules discussed)
- Giant Eagle, Inc. v. W.C.A.B. (Givner), 39 A.3d 287 (Pa. 2012) (statutory interpretation and broad construction principles)