PARSONS v. THE PHILADELPHIA PARKING AUTHORITY, 2:13-cv-00955

Parsons sued the Philadelphia Parking Authority (PPA) on behalf of herself and a class for unjust enrichment arising from metered parking payments during times when parking was free.
Plaintiff alleges she paid at kiosks in Center City after hours when no signs indicated free parking, on multiple occasions between Nov 24 and Dec 29, 2012.
Plaintiff seeks class certification, restitution of payments, pre- and post-judgment interest, and litigation costs.
PPA moved to dismiss plaintiff's unjust enrichment claim, arguing no benefit was conferred and governmental immunity.
The court granted the PPA’s motion, concluding PPA does not receive, accept, or retain benefits from class members due to statutory funding structure.
Statutory framework (Pennsylvania Parking Authorities Law) requires revenues from on-street parking to be transferred to the City and School District, not to the PPA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the unjust enrichment claim against PPA survives.	Parsons contends PPA benefitted from parking revenue despite allegations to the contrary.	PPA asserts it does not receive, retain, or benefit from on-street parking revenues per statute.	Unjust enrichment claim dismissed; no benefit to PPA under statute.

Allegheny Gen. Hosp. v. Phillip Morris, Inc., 228 F.3d 429 (3d Cir. 2000) (elements of unjust enrichment and inequitable retention outline)
Blount v. Phila. Parking Auth., 965 A.2d 226 (Pa. 2009) (statutory requirements govern PPA revenues and disposition)
City of Phila. v. Phila. Parking Auth., 798 A.2d 161 (Pa. 2002) (legislative use of PPA revenues and educational funding role)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standards after Iqbal; plausibility requirement)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (conclusory allegations insufficient; plausibility standard)