Southeastern Pennsylvania Transportation Authority v. City of Philadelphia
101 A.3d 79
| Pa. | 2014Background
- SEPTA faced seven FPO administrative complaints (2007–2009) in the Philadelphia Commission on Human Relations; SEPTA moved to dismiss for lack of jurisdiction.
- While those proceedings were pending, SEPTA filed a declaratory/injunctive action seeking a ruling that as a Commonwealth "agency and instrumentality" it is not subject to the Philadelphia Fair Practices Ordinance (FPO) or the Philadelphia Commission.
- The trial court dismissed SEPTA’s complaint; the Commonwealth Court reversed, holding SEPTA is a Commonwealth agency and within the Pennsylvania Human Relations Commission’s jurisdiction, so the Philadelphia Commission lacked jurisdiction and SEPTA need not exhaust administrative remedies.
- This Court granted review to clarify the standard for whether a municipal ordinance applies to a Commonwealth agency/instrumentality and to decide whether SEPTA had to exhaust administrative remedies.
- The Supreme Court held SEPTA need not exhaust administrative remedies when making a purely legal jurisdictional challenge, but vacated and remanded the Commonwealth Court because it failed to apply the Ogontz/Venango/Hazleton statutory-intent analysis to determine whether the legislature intended Philadelphia’s FPO (and the Philadelphia Commission) to have authority over SEPTA.
- The Court explained that designation as a Commonwealth "agency and instrumentality" is relevant but not dispositive; courts must examine legislative intent and, if not express, consider consequences of competing interpretations per Ogontz.
Issues
| Issue | Plaintiff's Argument (SEPTA) | Defendant's Argument (City/Philadelphia Commission) | Held |
|---|---|---|---|
| Whether SEPTA, statutorily declared an "agency and instrumentality" of the Commonwealth, is subject to Philadelphia's FPO and the Philadelphia Commission's jurisdiction | SEPTA: its enabling statute makes it a Commonwealth agency; absent clear legislative authorization, municipalities cannot exercise authority over the Commonwealth or its agencies; applying FPO to SEPTA risks regulatory chaos | City: Philadelphia is a home-rule municipality with authority to enact/enforce anti-discrimination ordinances (FPO); PHRA does not preempt the FPO; Ogontz requires a legislative-intent analysis and the FPO can apply to SEPTA | Court: designation as a Commonwealth agency is not dispositive; remanded for the Commonwealth Court to apply the Ogontz/Venango/Hazleton legislative-intent analysis to decide which entity the legislature intended to have preeminence |
| Whether SEPTA must exhaust administrative remedies before challenging the Philadelphia Commission's jurisdiction | SEPTA: may seek immediate declaratory relief for a purely legal challenge to agency jurisdiction | City: Commission competent to decide its own jurisdiction; SEPTA should first exhaust administrative process | Court: where the challenge is a purely legal question of jurisdiction, exhaustion is not required; SEPTA properly sought judicial relief |
Key Cases Cited
- Department of General Services v. Ogontz Area Neighbors Association, 505 Pa. 614 (establishing two-step legislative-intent/consequences test for conflicts between Commonwealth agencies and municipal regulation)
- County of Venango v. Borough of Sugarcreek, 534 Pa. 1 (applying Ogontz framework to resolve a county–borough land-use conflict)
- Hazleton Area School District v. Zoning Hearing Board, 566 Pa. 180 (applying Ogontz analysis to determine preeminence in land-use context)
- SEPTA v. Board of Revision of Taxes, 574 Pa. 707 (addressing SEPTA's tax immunity for property used for governmental purposes)
- Goldman v. SEPTA, 618 Pa. 501 (noting statutory classification of SEPTA as a Commonwealth agency but limiting implications for immunity and other rights)