Conflict Between a Specific and General Constitutional Provision
Where there is a conflict between a specific constitutional provision and certain general provisions which, but for such conflict, might apply, the specific provision will prevail:
In St. Aloysius R.C. Church v. Fayette County Bd. of Assessment Appeals, 849 A.2d 293 (Pa. Cmwlth. 2004), the Court rejected the appellant's alternative contention that the upper level of the parsonage was entitled to an exemption for an institution of purely public charity.
In St. Aloysius, the Court stated:
Were we to allow the Church to receive a tax exemption for what is essentially its "parsonage" under the more liberal purely public charity provision, where it is not operating an entity independent from the Church itself, we would essentially be giving greater effect to the more general constitutional provision allowing for a charitable tax exemption for institutions of purely public charity than to the more specific exemption for places of regularly stated worship.
This is contrary to the established principle of constitutional construction that, where there is a conflict between a specific constitutional provision, which is applicable to a particular case, and certain general provisions which, but for such conflict, might apply, the specific provision will prevail. Walsh v. Tate, 444 Pa. 229, 234, 282 A.2d 284, 287 (1971).
Further, this construction also would do violence to the presumption that every clause in a constitution is inserted for a useful purpose. See id. at 237, 282 A.2d at 288.
Thus, the Court must avoid a construction that would render any portion of the constitution meaningless. Id.