42 Pa. Cons. Stat. § 708

 Improvident administrative appeals and other matters.

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§ 708.  Improvident administrative appeals and other matters.

(a)  General rule.--No objection to a governmental determination shall be defeated by reason of error in the form of the objection or the office of clerk of court in which the objection is filed.

(b)  Appeals.--If an appeal is improvidently taken to a court under any provision of law from the determination of a government unit where the proper mode of relief is an action in the nature of equity, mandamus, prohibition, quo warranto or otherwise, this alone shall not be a ground for dismissal, but the papers whereon the appeal was taken shall be regarded and acted on as a complaint or other proper process commenced against the government unit or the persons for the time being conducting its affairs and as if filed at the time the appeal was taken.

(c)  Other matters.--If a complaint in the nature of equity, mandamus, prohibition, quo warranto or other original process is commenced in any court against a government unit or one or more of the persons for the time being conducting its affairs, as such, objecting to a governmental determination by any of them, where the proper mode of relief is an appeal from the determination of the government unit, this alone shall not be a ground for dismissal, but the papers whereon the process against the government unit or any of such persons was commenced shall be regarded and acted on as an appeal from such determination of the government unit and as if filed at the time such process was commenced.

(d)  Place of filing.--Section 5103 (relating to transfer of erroneously filed matters) shall also be applicable to an appeal or other matter which is deemed to be filed or commenced under any provision of this section.

(e)  Single form of action.--Where pursuant to general rules review of a determination of a government unit may be had by a petition for review or another single form of action embracing the appeal and actions in the nature of equity, mandamus, prohibition, quo warranto or otherwise, the jurisdiction of the appellate court shall not be limited by the provisions of 1 Pa.C.S. § 1504 (relating to statutory remedy preferred over common law), but such provisions to the extent applicable shall limit the relief available.

(Apr. 28, 1978, P.L.202, No.53, eff. 60 days)

 

1978 Amendment.  Act 53 added subsec. (e).

Cross References.  Section 708 is referred to in section 1722 of this title.

Notes of Decisions
Cited in 82 cases (6 in the last 5 years), 1978–2026 · leading case: Mercury Trucking, Inc. v. Pennsylvania Public Utility Commission
Mercury Trucking, Inc. v. Pennsylvania Public Utility Commission (2012) pa · cites it 3× “42 Pa.C.S. §§ 708(a)-(d); 5103(c). The Commonwealth Court’s transfer decision is a proper subject of plenary appellate review by this Court.”
Giovagnoli v. State Civil Service Commission (2005) pa · cites it 6× “The Commonwealth Court's order is vacated and the matter is remanded for further *400 consideration in accordance with this opinion.”
Hainsey v. Com. Pa. Liquor Control Bd. (1992) pa · cites it 6× “" Ostensibly on the basis that the order granting the continuance had not finally disposed of the litigation and thus was not a final order subject to appeal, the court regarded the petition as being governed by 42 Pa.C.S. § 708(b), which addresses disposition of "improvidently…”
Wortman v. Philadelphia Commission on Human Relations (1991) pacommwct · cites it 4× “However, if the trial court determines that Wortman made a proper request for further review, but that the commission has failed to comply with its duty, then the trial court, pursuant to 42 Pa.C.S. § 708(b), [2] should treat the appeal as if it were a complaint in a civil…”
In re Domestic Relations Hearing Room (2002) pacommwct · cites it 4× “42 Pa.C.S. § 708(a), (b). See also Pa. R.”
Pennsylvania Department of Aging v. Lindberg (1983) pa · cites it 2× “See 42 Pa.C.S. § 708(e) (single form of action) which provides as follows: (e) Single form of action.”
Guarrasi v. Scott (2011) pacommwct “§ 708(c) (original process complaint challenging government unit determination treated as an appeal of that determination), this Court may treat Plaintiff's filing as an RTKL appeal from Defendant Devlin Scott’s final response to Plaintiff's appeal of his RTKL request to…”
Burke, A., Aplt. v. Independence Blue Cross (2014) pa “42 Pa.C.S. § 708(b). The phrase, “or otherwise,” is plainly broad enough to include an action requesting declaratory and injunctive relief.”
SPS Technologies v. Workers' Compensation Appeal Board (2006) pacommwct · cites it 4× “SPS also argues that 42 Pa.C.S. § 708, which addresses improvident administrative appeals, is also relevant to this situation.”
Waters v. COM. DEPT. OF CORRECTIONS (1986) pacommwct · cites it 2× “Having found that petitioners complaint is not a proper action in mandamus, we must now review the action in light of Section 708(c) of the Judicial Code, 42 Pa. C. S. §708(c). Section 708(c) provides that where ah action is commenced in mandamus and is later determined not to…”
Stoner v. Township of Lower Merion (1991) pacommwct · cites it 2× “See 42 Pa.C.S. § 708. Moreover, because mandamus is appropriate here, where compliance is clear, the peremptory mandamus rule is available, as sought to be invoked by the landowners' Count II.”
Mercury Trucking, Inc. v. Pennsylvania Public Utility Commission (2007) pacommwct · cites it 4× “Accordingly, pursuant to 42 Pa.C.S. § 708, [4] we will transfer this matter to our original jurisdiction and direct the Commission to file a responsive pleading.”
— 42 Pa. Cons. Stat. § 708(a) — 14 cases
Mercury Trucking, Inc. v. Pennsylvania Public Utility Commission (2012) pa “42 Pa.C.S. §§ 708(a)-(d); 5103(c). The Commonwealth Court’s transfer decision is a proper subject of plenary appellate review by this Court.”
Giovagnoli v. State Civil Service Commission (2005) pa “The Commonwealth Court's order is vacated and the matter is remanded for further *400 consideration in accordance with this opinion.”
Gardner v. Jenkins (1988) pacommwct
In re Domestic Relations Hearing Room (2002) pacommwct “42 Pa.C.S. § 708(a), (b). See also Pa. R.”
— 42 Pa. Cons. Stat. § 708(b) — 21 cases
Hainsey v. Com. Pa. Liquor Control Bd. (1992) pa “" Ostensibly on the basis that the order granting the continuance had not finally disposed of the litigation and thus was not a final order subject to appeal, the court regarded the petition as being governed by 42 Pa.C.S. § 708(b), which addresses disposition of "improvidently…”
Wortman v. Philadelphia Commission on Human Relations (1991) pacommwct “However, if the trial court determines that Wortman made a proper request for further review, but that the commission has failed to comply with its duty, then the trial court, pursuant to 42 Pa.C.S. § 708(b), [2] should treat the appeal as if it were a complaint in a civil…”
Mercury Trucking, Inc. v. Pennsylvania Public Utility Commission (2012) pa “42 Pa.C.S. §§ 708(a)-(d); 5103(c). The Commonwealth Court’s transfer decision is a proper subject of plenary appellate review by this Court.”
Burke, A., Aplt. v. Independence Blue Cross (2014) pa “42 Pa.C.S. § 708(b). The phrase, “or otherwise,” is plainly broad enough to include an action requesting declaratory and injunctive relief.”
In re Domestic Relations Hearing Room (2002) pacommwct “42 Pa.C.S. § 708(a), (b). See also Pa. R.”
— 42 Pa. Cons. Stat. § 708(c) — 26 cases
Guarrasi v. Scott (2011) pacommwct “§ 708(c) (original process complaint challenging government unit determination treated as an appeal of that determination), this Court may treat Plaintiff's filing as an RTKL appeal from Defendant Devlin Scott’s final response to Plaintiff's appeal of his RTKL request to…”
Waters v. COM. DEPT. OF CORRECTIONS (1986) pacommwct “Having found that petitioners complaint is not a proper action in mandamus, we must now review the action in light of Section 708(c) of the Judicial Code, 42 Pa. C. S. §708(c). Section 708(c) provides that where ah action is commenced in mandamus and is later determined not to…”
— 42 Pa. Cons. Stat. § 708(d) — 2 cases
— 42 Pa. Cons. Stat. § 708(e) — 4 cases
Pennsylvania Department of Aging v. Lindberg (1983) pa “See 42 Pa.C.S. § 708(e) (single form of action) which provides as follows: (e) Single form of action.”
Mercury Trucking, Inc. v. Pennsylvania Public Utility Commission (2012) pa “42 Pa.C.S. §§ 708(a)-(d); 5103(c). The Commonwealth Court’s transfer decision is a proper subject of plenary appellate review by this Court.”
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