City of Philadelphia v. Schweiker, 579 Pa. 591

Summary

The Supreme Court of Pennsylvania reviewed a direct appeal concerning amendments to Pennsylvania's Parking Authority Law that transferred control of the Philadelphia Parking Authority's governing board from the Mayor of Philadelphia to the Governor. The court addressed standing and constitutional challenges involving home rule, legislative pledges, special legislation, delegation of municipal functions, and the single-subject rule. The provided text does not include the conclusion of the opinion.

Holdings

1. Act 22 validly limits Philadelphia's home-rule authority by transferring control over Parking Authority appointments to the Governor. A parking authority is an agency of the Commonwealth rather than an instrumentality of the City, and the General Assembly may impose limitations on municipal home-rule powers through legislation applicable to first-class cities.
2. The City had standing to assert Counts II through V because its alleged status as guarantor of Parking Authority bonds created a sufficient direct financial interest; Mayor Street lacked standing on those counts because he did not claim to be a bondholder or identify an effect on his official powers or obligations.
3. Section 12's prohibition against actions impairing bondholder security restricted the Authority's existing powers but did not constitute a legislative pledge never to alter those powers. In any event, Act 22 did not violate the provision because it protected debt-service and bond-retirement obligations.
4. Act 22 did not violate Section 13's pledge not to limit or alter the Authority's rights before its bonds were retired because the amended law preserved the primacy of bondholders' interests. The alleged change also did not establish impairment of contractual obligations.
5. The claims alleging special legislation, inadequate publication, improper delegation, and violation of the single-subject rule were abandoned because the appellants did not include them in the questions presented, develop them in the appellate brief, or request relief on them.

Questions Presented

1. Whether Act 22 impermissibly limited Philadelphia's home-rule powers by transferring appointment authority over the Philadelphia Parking Authority from the mayor to the Governor.
2. Whether the City had standing to challenge Act 22 based on its asserted financial exposure as guarantor of Parking Authority bonds.
3. Whether the statutory restrictions protecting bondholders constituted an enforceable pledge that Act 22 violated.
4. Whether the transfer of available retained earnings to the Philadelphia School District impaired contractual obligations in violation of the Contract Clause.
5. Whether the City's reliance on the prior statutory scheme created an estoppel-based constitutional claim.
6. Whether the remaining constitutional claims were preserved for appellate review.

Disposition

affirmed