730 C.D. 2025
Pa. Commw. Ct.Jul 28, 2026Background
- The Salvation Army owns about 1,200 acres in Wayne County comprising Camp Ladore Retreat and Conference, with Lake Ladore and related facilities. 1
- A prior 1993 case held portions of the property, including Lake Ladore, Ladore Lodge, and outdoor amphitheaters, tax exempt. 2
- That prior case found The Salvation Army qualified as an institution of purely public charity under HUP. 3
- Act 55 codified charity-exemption criteria and preserves parcel-by-parcel review of whether property is used to advance charitable purposes. 4
- The Board denied exemption for several Camp Ladore parcels because The Salvation Army allegedly failed to prove each parcel separately relieved government burden. 5
- The trial court affirmed, and The Salvation Army appealed arguing the court wrongly applied HUP/Act 55 to each parcel. 6
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Must each tax parcel separately satisfy HUP/Act 55? 7 | Salvation Army says its organizational charity status controls; each parcel need only be used for its charitable purposes. | Board says each parcel must independently show all HUP/Act 55 factors, including relieving government burden. | No; parcel review asks only whether property is actually and regularly used for charitable purposes. 8 |
| Did Camp Ladore parcels support the exemption? 9 | Salvation Army says the whole property supports camps, retreats, veteran services, rehab, worship, and staff training. | Board says the record does not show each parcel relieves government burden. | Yes; undisputed uses of the entire property advance Salvation Army's charitable mission. 10 |
Key Cases Cited
- Hospital Utilization Project v. Commonwealth, 487 A.2d 1306 (Pa. 1985) (sets the HUP factors for purely public charity status 11)
- Alliance Home of Carlisle v. Bd. of Assessment Appeals, 919 A.2d 206 (Pa. 2007) (parcel review turns on actual and regular use, not separate HUP status for each parcel 12)
- Chartiers Valley School District v. Board of Property Assessment, Appeals, Review and Registry, 794 A.2d 981 (Pa. Cmwlth. 2002) (explains Act 55 evaluates the institution as the basic unit, not divided parcels 13)
- Goodwill Industries of North Central Pennsylvania, Inc. v. Centre County Board of Assessment Appeals, 323 A.3d 887 (Pa. Cmwlth. 2024) (involved a different exemption issue and did not control parcel-use analysis 14)