Filing An Appeal to the Court of Common Pleas Under the Liquor Code

Can Persons Not Entitled to Appeal to Court of Common Pleas Under Liquor Code Appeal Against a Board's Decision Under the Administrative Agency Law ? In Application of El Rancho Grande, Inc., 496 Pa. 496, 437 A.2d 1150 (1981), involving a claimed resort area exception to the established quota of restaurant liquor licenses, the court noted that persons not entitled to file appeals to the court of common pleas under the Liquor Code may still have standing to appeal from a Board decision under Section 702 of the Administrative Agency Law, 2 Pa. C.S. 702, if they are aggrieved by the decision. The court concluded that individual licensees had standing because they asserted an interest different from that common to all citizens but that the association, which did not appear at the hearing, lacked standing to appeal. In Application of Family Style Restaurant, Inc., 503 Pa. 109, 468 A.2d 1088 (1983), also involving a claimed resort area exception, the court held that the association did not present evidence that it or its members would suffer direct, substantial and immediate harm and that the bare allegation of future economic injury was not enough.