HomeMy WebLinkAbout02-1916 CivilSOUTH NEWTON
TOWNSHIP ELECTORS
V.
SOUTH NEWTON
TOWNSHIP SUPERVISOR
RONALD BOUCH
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-1916 CIVIL TERM
CIVIL ACTION - LAW
IN RE: PRELIMINARY OBJECTION
TO AMENDED COMPLAINT AND DEMURRER
BEFORE HOFFER, P.J., OLER, GUIDO, JJ.
OPINION AND ORDER OF COURT
Petitioners are residents of South Newton Township, Cumberland County,
Pennsylvania. They are seeking to remove respondent Ronald Bouch from his position as
township supervisor for the alleged failure to properly perform his duties. The action is
premised upon Section 503 of the Second Class Township Code which provides:
Removal for failure to perform duties
If any township officer fails to perform the duties of the office, the court
of common pleas upon complaint in writing by five percent of the electors
of the township may issue a rule upon the officer to show cause why the
office should not be declared vacant. The officer shall respond to the rule
within thirty days from its date of issue. Upon hearing, the court may
declare the office vacant and require the vacancy to be filled under section
407.
53 P.S. § 65503.
Respondent has filed preliminary objections in the nature of a demurrer. He
argues that Article VI Section 7 of the Pennsylvania Constitution provides the exclusive
NO. 2002-1916 CIVIL
method for the removal of township officials. ~ He further contends that Section 503 of
the Second Class Township Code, being in conflict with Article VI Section 7, is
unconstitutional. We are constrained to agree.
Our Supreme Court faced this identical issue in the case of In re: Petition to
Reca//Reese, 542 Pa. 114, 665 A.2d 1162 (1995). It held that Article VI Section 7 of the
Pennsylvania Constitution "indisputably applies to all elected officers, and sets forth in
unambiguous language the exclusive method.., of removing such elected officers."
(emphasis in original), quoting from Citizens Committee to Recall Rizzo v. Board of
Elections, 470 Pa. at, 38, 367 A.2d at 250-51 (1976); 665 A.2d at 1167.
Petitioners argue that the above language in Reese was dicta and is, therefore, not
binding upon this Court. They contend that Reese and Rizzo both involved recall
provisions enacted by local municipalities under their Home Rule Charters while the
instant case involves an act of the legislature. They further argue that no court has ever
held the recall provisions of Section 503 to be unconstitutional.
The fatal flaw in petitioners' argument stems from the Reese Court's reference to
the case of In re: Supervisors of Milford Township, 291 Pa. 46, 139 A. 623 (1927). The
Milford Court was asked to decide whether Section 192 of the General Township Act of
July 14, 1917, conflicted with Article VI Section 4 of the Pennsylvania Constitution of
Article VI Section 7 of the Pennsylvania Constitution provides:
Removal of civil officers
All civil officers shall hold their offices on the condition that they behave themselves well while in
office, and shall be removed on conviction of misbehavior in office or of any infamous crime.
Appointed civil officers, other than judges of the courts of record, may be removed at the pleasure
of the power by which they shall have been appointed. All civil officers elected by the people,
except the Governor, the Lieutenant Governor, members of the General Assembly and judges of
the courts of record, shall be removed by the Governor for reasonable cause, after due notice and
full hearing, on the address of two-thirds of the Senate.
NO. 2002-1916 CIVIL
1874.2 The lower court had ruled that it did, thus declaring Section 192 to be
unconstitutional. The Supreme Court reversed. In the Reese case the Pennsylvania
Supreme Court unanimously held that "Milford... was wrongly decided, and it is hereby
overruled." Reese, supra at 1167.
We are bound by the principles of stare decisis to follow the pronouncement of
our Supreme Court that Article VI Section 7 of the Pennsylvania Constitution sets forth
the exclusive method for removing elected officials. Any act of the legislature, including
the act at issue in this case, which is contrary to this proposition, is unconstitutional.
Therefore, petitioners' action must be dismissed.
ORDER OF COURT
AND NOW, this 6TM day of SEPTEMBER, 2002, for the reasons set forth in the
accompanying opinion Respondent's preliminary objections are sustained and this action
is dismissed with prejudice.
By the Court,
/s/George E. Hoffer
George E. Hoffer, P.J.
Jason Kutulakis, Esquire
Matthew J. Eshelman, Esquire
:sld
: Section 192 of the General Township Act of 1914 set forth the procedure for removal of township officers
and is the predecessor to Section 503 of the Second Class Township Code. Article VI § 4 of the
Pennsylvania Constitution of 1874 was renumbered in 1966 as Article VI § 7.