Pennsylvania Sch. Bds. Ass'n, Inc. v. Commonwealth Ass'n of Sch. Adm'rs, Teamsters Local

In Pennsylvania Sch. Bds. Ass'n, Inc. v. Commonwealth Ass'n of Sch. Adm'rs, Teamsters Local, 502, 696 A.2d 859 (Pa. Cmwlth. 1997), the Court determined that then Governor Ridge was not an indispensable party merely because he gave final approval of the statute at issue by signing it into law. In so holding, we noted that the challenged legislation did not give the Governor any powers or duties with respect to the legislation's enforcement or administration and that a contrary holding would have the effect of having him become an indispensable party to every action challenging the constitutionality of legislation. Further, the Court concluded that the Secretary of Education was not an indispensable party because he had no power or duty to enforce, implement or administer the challenged statute.