Can Charity (Legally) Benefit Only Poor Persons or Also the Rich ?
In Unionville-Chadds Ford School District v. Chester County Board of Assessment Appeals, 552 Pa. 212, 714 A.2d 397 (1998) Ford School District, when reviewing whether real property owned Longwood Gardens, Inc. was exempt from real estate tax, the Supreme Court rejected the notion that the general public cannot be a subject of charity because such a class of beneficiaries would not be limited to those who are incapacitated or financially distressed.
In so doing, the Supreme Court held that the beneficiaries of charity need not be limited to those who are in distress and that there is no requirement that all of the benefits bestowed by a purely public charity go only to the financially needy. Unionville-Chadds Ford School District, 552 Pa. at 219, 714 A.2d at 400.
The Supreme Court stated further that "an essential feature of public charity 'is that it is not confined to privileged individuals, but is open to the indefinite public.
It is this indefinite public or unrestricted quality that gives it its public character.'" Id. at 220, 714 A.2d at 401 (quoting Donohugh's Appeal, 86 Pa. 306, 313, 5 Week. Notes Cas. 196 (1878)).
In other words, a charity can benefit all persons without regard to economic status or whether such persons are rich or poor but the requirement remains that an entity must benefit a substantial and indefinite class of persons (regardless of economic status) who are legitimate subjects of charity in order to meet the constitutional qualifications as a purely public charity.