Does the Existence of Adequate Statutory Remedies Make It Inappropriate for a Court to Exercise Jurisdiction ?
Does the Existence of Adequate Statutory Remedies Make it Inappropriate for a Court to Exercise Jurisdiction Over Taxpayers' Uniformity Clause Challenge ?
In Jordan v. Fayette County Bd. of Assessment Appeals, 782 A.2d 642 (Pa. Cmwlth. 2001), the trial court sustained the Board's preliminary objections and dismissed taxpayers' class action civil rights complaint on the ground the court lacked subject matter jurisdiction because taxpayers did not exhaust their administrative appeals.
On appeal to this Court, taxpayers argued they should have been permitted to pursue their civil rights action because their remedies under the Fourth through Eighth Class County Assessment Law (County Assessment Law) were constitutionally inadequate.
They further argued their Uniformity Clause challenge is such that they should be excused from exhausting their statutory remedies.
In Jordan the Court cited Murtagh v. County of Berks, 715 A.2d 548 (Pa. Cwmlth. 1998) and held that the existence of adequate state law remedies barred taxpayers from maintaining their equal protection challenge under 42 U.S.C. 1983.
The Court further held the existence of adequate statutory remedies made it inappropriate for this Court to exercise equity jurisdiction over taxpayers' Uniformity Clause challenge.