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5 Pennsylvania opinions name it 2 courts 2016–2026 3 in the last five years
The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
J.J. Loughran v. Valley View Developers, Inc. ~ Appeal of: Estate of Milton Parker, Inc.green2 sentences2026The merger of lots doctrine is “only triggered where a local municipality has adopted a merger of lots provision.” Loughran, 145 A.3d at 822 . 2026For the doctrine to be invoked, there must be a provision in the zoning ordinance that requires a merger of two lots, in common ownership. . . .” Id. at 687 ; see also Loughran v. Valley View Devs., Inc., 145 A.3d 815, 817 (Pa. Cmwlth. 2015) (stating that “the merger of lots doctrine has no application to a nonconforming lot located 9 in a jurisdiction where the zoning ordinance adopted by the local governing body does not contain a merger of lots provision”). | 3 | 4 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In Re: Appeals of A.K. Jerrehian, Jr. From the Decision Dated December 9, 2014 of the ZHB of The Twp. of Lower Merion
green
1 sentence2026For the doctrine to be invoked, there must be a provision in the zoning ordinance that requires a merger of two lots, in common ownership. . . .” Id. at 687 ; see also Loughran v. Valley View Devs., Inc., 145 A.3d 815, 817 (Pa. Cmwlth. 2015) (stating that “the merger of lots doctrine has no application to a nonconforming lot located 9 in a jurisdiction where the zoning ordinance adopted by the local governing body does not contain a merger of lots provision”). | 1 | 2026–2026 |
Kreamer v. Fleming
neutral
1 sentence2025And this doctrine has been consistently applied in the courts of this state.”) (citing Kreamer v. Fleming, 43 A. 388 (Pa. 1899)).14 ____________________________________________ 14 The doctrine of merger of estates is not to be confused with the doctrine of merger of lots, which is concerned with the physical merger of parcels of land. | 1 | 2025–2025 |
Springfield Township v. Halderman
green
1 sentence2016In Springfield Township v. Halderman , 840 A.2d 528 (Pa.Cmwlth.2004), the landowners acquired two lots by a single deed containing a separate legal description for each lot and subsequently deeded the two lots back to themselves via two separate deeds. | 1 | 2016–2016 |
Township of Middletown v. Middletown Township Zoning Hearing Board
green
2 sentences2016Township of Middletown v. Middletown Township Zoning Hearing Board , 120 Pa.Cmwlth. 238 , 548 A.2d 1297 , 1299 (1988). 2016Township of Middletown v. Middletown Township Zoning Hearing Board , 120 Pa.Cmwlth. 238 , 548 A.2d 1297 , 1299 (1988). | 1 | 2016–2016 |
Cottone v. ZONING HEARING BD. OF POLK TP.
green
1 sentence2016Cottone , 954 A.2d at 1276 -1277 . | 1 | 2016–2016 |