Narrative Opinion Summary
This case involves United Artists Theatre Circuit, Inc., which sought approval from Warrington Township for a multiplex theater development. United Artists alleged that the Township and its Board of Supervisors unlawfully delayed their project to favor a competitor, Regal Cinema, which agreed to pay an annual 'impact fee' to the Township. The case focused on whether the Supervisors' actions violated United Artists' substantive and procedural due process rights under 42 U.S.C. § 1983. Initially, the District Court partially granted summary judgment, denying the Supervisors' qualified immunity claims on substantive due process grounds but granting it on procedural due process claims. The appellate court vacated this decision, directing an individual assessment of each Supervisor's qualified immunity claim, emphasizing the need for conduct that 'shocks the conscience' to establish a substantive due process violation as per *County of Sacramento v. Lewis*. The case highlights the conflict between the 'improper motive' test and the 'shocks the conscience' standard, with the court ultimately vacating the denial of the Supervisors' summary judgment motion and remanding for further proceedings. The decision underscores the complexity of applying constitutional standards in land use and municipal governance contexts.
Legal Issues Addressed
Application of Impact Fees under Pennsylvania Lawsubscribe to see similar legal issues
Application: The court noted that the Supervisors did not claim authority under Pennsylvania law regarding municipal impact fees, highlighting the alleged improper motives for delaying United Artists' proposal.
Reasoning: The Honorable Alan D. Lourie, Circuit Judge for the U.S. Court of Appeals for the Federal Circuit, addressed several legal principles under Pennsylvania law regarding municipal 'impact fees' for public transportation improvements.
Law-of-the-Case Doctrinesubscribe to see similar legal issues
Application: The current panel's decision was not bound by the previous panel's determination regarding the substantive due process standard, allowing reconsideration of the applicable legal framework.
Reasoning: The law-of-the-case doctrine does not prevent the current panel from considering an issue regarding the 'shocks the conscience' standard in relation to substantive due process claims.
Procedural Due Process Claimssubscribe to see similar legal issues
Application: The District Court granted summary judgment for the procedural due process claims, as the evidence did not support a violation of procedural due process rights.
Reasoning: The Supervisors claimed qualified immunity and sought summary judgment, which the District Court partially granted, denying the motion regarding substantive due process but granting it for procedural due process.
Qualified Immunity in Land Use Disputessubscribe to see similar legal issues
Application: The court evaluated the Supervisors' claims of qualified immunity, requiring a separate assessment for each official's conduct to determine if their actions violated clearly established constitutional rights.
Reasoning: The appellate panel thereafter vacated the District Court's order, directing it to individually assess each Supervisor's qualified immunity claim.
Substantive Due Process and the 'Shocks the Conscience' Standardsubscribe to see similar legal issues
Application: The court emphasized that substantive due process violations require conduct that is so egregious it 'shocks the conscience,' moving beyond mere improper motives as previously applied in land-use cases.
Reasoning: The case at hand is not exempt from the 'shocks the conscience' test established in Lewis, despite being a land use dispute.