Beattie v. Allegheny County - Pennsylvania Supreme Court - October 11, 2006
majority http://www.courts.state.pa.us/OpPosting/Supreme/out/J-87B-2005mo.pdf
concurring http://www.courts.state.pa.us/OpPosting/Supreme/out/J-87B-2005mo.pdf
Taxpayers permitted to bypass administrative procedures -- i.e., not required to exhaust administrative remedies - and bring an "equitable class action" challenged the county real estate assessment system which they alleged had "systemic flaws" and violated the uniformity clause of the state constitution, Article VIII, sec. 1.
This was held to be one of those "rare cases, as exception to the exhaustion rule" because "the balance between an administrative agency's exercise of its expertise and its ability to offer complete redress for an alleged wrong of egregious constitutional dimension falls in favor of proceeding in equity in the trial court."
In order to invoke equity jurisdiction, a plaintiff must satisfy a two-part test: "the taxpayers must (1) raise a substantial constitutional issue, and (2) lack an adequate remedy through the [statutory] administrative appeal process."
The court discussed the legislature's "power to channel all issues, including constitutional ones, into a specified route of appeal, such as an administrative appeal" but recognized "an exception for certain types of constitutional questions that the administrative process was ill-suited to resolve...[B]ypassing the agency process within the framework of a direct attack on the enabling statute is inherently less likely to do violence to the agency's role as fact-finder and applier of specialized expertise that in the context of an 'as applied' challenge." The court discussed the "admonition that, 'where relying solely on the statutory appeal mechanism would result in a 'multiplicity of duplicative lawsuits and, in contrast, an action in equity would provide a tidy global resolution,' the legal remedy should be deemed inadequate." In such a case, a "complaint can be facially tested against constitutional norms unaided by agency expertise...."
In a concurring opinion, Chief Justice Cappy said that the majority's test was "incomplete" and missed an "important factor" in the court's exhaustion-of-remedies doctrine - whether administrative input would be helpful. The justice felt that the majority failed to give the agency's role sufficient deference, because of agency expertise or because an agency interpretation would be desirable.
