Addiction Specialists, Inc. v. Hampton Twp.,
411 F.3d 399 (3rd Cir. 2005)
A drug rehabilitation clinic operator submitted a change of use application in order to open a new methadone clinic in an area zoned as highway commercial. Under MPC Section 621, such clinics may not be closer than 500 feet to public facilities including schools and parks. The Township held a public meeting on the application and concluded that the facility would violate Section 621 because it was within 500 feet of a travel agency that qualified as a school because it hosted a travel and tourism class for the local community college. In addition, the facility was within 500 feet of a museum, which, according to the township, qualified it as a “public park.” Accordingly the township denied the application.
The clinic operator appealed in both state and federal court. In state court, the clinic operator alleged that the township’s interpretation of Section 621 was arbitrary and capricious. In addition, it alleged violations of the Pennsylvania Human Relations Act, the Americans with Disabilities Act, and the Rehabilitation Act. In federal court, the clinic operator asserted Section 1983 violations of its due process and equal protection rights under the United States Constitution, violations of the Americans with Disabilities Act and the Rehabilitation Act, and the unconstitutionality of MPC Section 621.
The federal district court dismissed all of the clinic operator’s counts because, under its view of Younger, the land use appeal was ongoing in state court, hearing the case in the federal courts would interfere with important state interests, and state court afforded the clinic operator an adequate forum in which to bring its federal claims.
On appeal, the Third Circuit affirmed in part and reversed in part. It affirmed only the lower court’s decision to abstain from deciding the constitutionality of Section 621. The Third Circuit held that there were no important state interests implicated in deciding whether the individual local officials’ actions violated state or federal law. In addition, it held that because Pennsylvania courts do not award damage in land use appeals, the district court should have retained jurisdiction over all claims for which damages were sought as a remedy; however, it directed the district court to stay the hearing of such claims until it was clear that no damages would be awarded at the state level.
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