DISSENTING OPINION BY
Judge PELLEGRINI.Imagine your credit card company has consistently charged you unlawful fees— tripling your bill. Upon realizing this illegality, you sue the credit card company to recover those fees. A month later, a law is enacted that says the credit card company cannot only charge those fees in the fu*357ture, but can recover those fees it illegally imposed in the past. If that legislation is constitutional, what is the result? The credit card company receives a windfall, and you are left without a remedy to be reimbursed for illegally charged fees that tripled your monthly credit card payment.
That windfall is essentially what was allowed to occur with regard to municipal liens with the passage of Act 20. Under Act 20, municipalities, their appointed agents, or the companies that purchase tax hens from municipalities are allowed to collect legal fees incurred during the collection of delinquent taxes dating back to 1996 under the Municipal Claims and Tax Liens Act (Tax Lien Law). In effect, some companies that purchase the hens or law firms that are engaged in the business of collecting the hens make their money on the amount of the fees that can be imposed. The net result in this case is that the named plaintiffs were required to pay triple the amount of the underlying hen because of the imposition of attorney’s fees — even though no such authority existed at the time that those fees were imposed. To foreclose that result, the electors of the Commonwealth adopted Article 1, § 11 of the Pennsylvania Constitution to preclude the legislature from retroactively sanctioning actionable conduct by providing that no cause of action that had accrued could be vitiated by act of the legislature. While the majority found that attorneys’ fees collected before the passage of Act 20 could not be retroactively legalized back to 1996, I believe that Act 20 is unconstitutional under Article 1, Section 11 of the Pennsylvania Constitution with respect to all claims filed prior to the effective date of its passage. Accordingly, for the foregoing reasons, I respectfully dissent.
Jerry and Theodara Konidaris, husband and wife, (collectively, Konidaris) are the record owners of certain real property situated in the City of McKeesport, Allegheny County, Pennsylvania (the Property). Konidaris failed to pay property taxes levied by the McKeesport School District (District) for calendar years 1998, 1999, 2000, and 2001, which totaled $2,147.59 (Tax Claim). The Tax Claim was secured by liens against the Property in favor of the District (Tax Liens).
Portnoff Law Associates, Ltd. (Portnoff) is a law firm engaged by more than 40 municipalities and school districts to collect delinquent taxes and initiates Sheriffs sale proceedings as part of its method to collect such taxes. The District hired Portnoff to collect the Konidaris Tax Claim.
In addition to the face amount of the Tax Claim, Portnoff added various fees to the amount, including attorneys’ fees, increasing the total amount of the Tax Claim to $5,927.52, nearly tripling the original amount of the taxes pursuant to Section 3 of the Tax Lien Law, 53 P.S. § 7106. In addition, Portnoff initiated Sheriffs sale proceedings against the Property on behalf of the School District for the 1998 and 1999 tax years, and the sale was scheduled for April 7, 2003, to satisfy the claimed amounts, including attorneys’ fees and expenses. Those proceedings, however, were stayed by the Court of Common Pleas of Allegheny County (trial court) pending the outcome of this litigation.
On March 19, 2003, the Supreme Court of Pennsylvania rendered its decision in Pentlong Corp. v. GLS Capital, Inc., 573 Pa. 34, 820 A.2d 1240 (2003). Our Supreme Court held in that case, inter alia, that it was illegal for a municipality or school district to collect its own attorneys’ fees incurred while collecting delinquent taxes pursuant to Section 3 of the Tax Lien Law. On March 28, 2003, Konidaris filed a class action complaint on behalf of themselves and others similarly situated *358seeking declaratory relief, injunctive relief, and punitive damages against Portnoff, claiming that under our Supreme Court’s recent decision in Pentlong, Portnoffs attempt to collect attorneys’ fees was illegal. The three counts listed in the complaint were (1) declaratory judgment; (2) unjust enrichment; and (8) fraud.
On August 14, 2003, apparently in response to the Pentlong decision, the General Assembly passed Act 20 of 2003, which amended the Tax Lien Law. Under Section 2 of Act 20 (which amends Section-3 of the Tax Lien Law), municipalities and school districts are now authorized to collect reasonable attorneys’ fees incurred during the collection of delinquent taxes under the Tax Lien Law. Under Section 10 of Act 20, the General Assembly pronounced that the amendments to Section 3 of the Tax Lien Law apply “retroactively to January 1,1996.”
Based on Act 20, Portnoff took the position in the Konidaris class action that its collection of attorneys’ fees had been retroactively legalized, and that the imposition of the fees associated with the Koni-daris Tax Claim (which were invalidated by Pentlong) were validated by Act 20. Konidaris then filed for summary judgment based on their assertion that Act 20 was unconstitutional retroactive legislation in violation of Article 1, Section 11 of the Pennsylvania Constitution. Portnoff also filed its own motion for partial summary judgment.
The trial court denied summary judgment to Konidaris and granted summary judgment to Portnoff, reasoning that Act 20 was constitutional and did not imper-missibly extinguish any vested rights of Konidaris or other similarly situated plaintiffs. The trial court reasoned that Pentlong did not create a cause of action for Konidaris (i.e., an action to recover illegally charged attorneys’ fees). The trial court also reasoned that the mere personal expectation that Konidaris and others similarly situated had that they would never have to pay attorneys’ fees when their tax delinquencies and real estate liens were resolved was not the type of vested right that the Pennsylvania Constitution and the United States Constitution protected. Finally, the trial court reasoned that Act 20’s retroactive application satisfied due process because it was merely a remedial, curative, or validating amendment, the ret-roactivity of which was not barred by the Pennsylvania Constitution. Following that ruling, Konidaris filed a Petition for Permission to Appeal the interlocutory order denying summary judgment which was granted by the trial court.
On appeal to this Court, the majority dismisses the declaratory judgment count under Section 7540(b) of the Judicial Code, 42 Pa.C.S. § 7540(b) — which provides that in tax matters, the appropriate taxing authorities must be served with process— reasoning that although Konidaris and others similarly situated had an accrued cause of action for declaratory relief at least at the time they filed suit, they failed to join the taxing authority (i.e., McKeesport Area School District), rendering this count dismissible. As to the unjust enrichment count, the majority holds that Act 20 could not be applied to the attorneys’ fees “actually recovered” by Portnoff before the passage of Act 20 (on August 14, 2003) because a cause of action accrued for unjust enrichment as to those fees; however, as to the fees not actually “received” by Port-noff before August 14, 2003, the cause of action for unjust enrichment was incomplete, thereby allowing Portnoff to invoke Act 20 and recover. Finally, the majority holds that because Konidaris failed to plead “reliance” (a necessary element of fraud), no cause of action for fraud commenced before Act 20. Because I would *359hold that Act 20 violates Article 1, Section 11 of the Pennsylvania Constitution by retroactively changing not only the Konidaris law suit, but the terms of each of the Konidaris hens that were established well before Act 20 was enacted, I respectfully dissent.
First and foremost, it is helpful to understand at the outset the nature of municipal tax hens. Municipal tax hens are statutory hens and, as such, are governed strictly by the statute under which the hens were created. Spring Garden Township v. Logan, 149 Pa.Super. 580, 27 A.2d 419 (1942). In simple terms, the taxing authorities cannot impose upon taxpayers that which has not been authorized specifically by statute. See 14 Eugene McQuillan, The Law of Municipal CORPORATIONS § 88.161, at 470-71 (3d ed. 1998). Once the taxes become past due, the taxing authority is empowered to perfect its hen (within 3 years from the date the taxes are due) and to charge interest at a rate not to exceed 10% from the date the hen is filed (i.e., perfected). 53 P.S. § 7143; Chartiers Valley School District v. Virginia Mansions Apartments, Inc., 340 Pa.Super. 285, 489 A.2d 1381 (1985). Just like any other hen, the amount owed once the hen is filed is fixed and cannot be changed or amended after it becomes operative; the only changes that are authorized by statute are those that, for example, change minor errors in the filing. 53 P.S. § 7144. Local taxing authorities can also charge certain costs and fees associated with the collection of delinquent taxes, 53 P.S. § 7106, but they could not, as of January 17, 2003 (when Portnoff attempted to collect the delinquent amounts in this case), charge any attorneys’ fees under the Tax Lien Law for recovery of delinquent taxes. See formerly 53 P.S. § 7106; Pentlong. It appears that any fee incurred in attempting to collect on the hen merges into the underlying hen. 53 P.S. § 7106(a). If the property is sold at judicial sale to collect the underlying lien and it is insufficient to pay the amount claimed, the property owner at the time the fee is owed is still personally obligated to pay any deficiency. See 53 P.S. § 7251; 53 P.S. § 7101.
For lack of a better term then, each of the Konidaris tax hens from 1998-2001 were “set in stone” in terms of their amount as of the date the taxing authority filed the claim for delinquent taxes. They included, as the statute dictated at the time the hens were filed, the amount of the underlying tax plus interest, if any, from the date each hen was filed, and costs, if any, associated with the collection, excluding attorneys’ fees. As of January 17, 2003, when Portnoff tripled the amount of the underlying hen by adding attorneys’ fees into the mix without the apparent authority to do so under the Tax Lien Law, Konidaris’ obligations under the tax hen for each tax year was substantially changed, as everyone would agree, and accordingly, Konidaris sued to establish their rights about two months later.
With that backdrop in mind, the fundamental issue as presented to us by the parties becomes clear: Can legislation retroactively change the economic obligations of parties to an existing cause of action by retroactively sanctioning actionable conduct that was being redressed in an existing cause of action? In my view, the retroactive application of Act 20 strips Konidaris and similarly situated plaintiffs of their existing “remedy” to be free from paying attorneys’ fees where no such authority existed to impose those fees under the Tax Lien Law at the time their cause of action arose. That remedy was duly invoked under our Supreme Court’s decision in Pentlong and cannot, by any act of the General Assembly, be disturbed without running afoul of the Pennsylvania Constitution.
*360The Pennsylvania Constitution (and the constitutions of at least 39 other states) contains a provision requiring, inter alia, that a person receive a remedy by “due course of law” for an injury done to him or her. See Pa. Const, art. 1, § 11. Specifically, Article 1, § 11 of the Pennsylvania Constitution provides as follows:
All courts shall be open; and every man for an injury done him in his lands, goods, person or reputation shall have remedy by due course of law, and right and justice administered without sale, denial or delay. Suits may be brought against the Commonwealth in such manner, in such courts and in such cases as the Legislature may by law direct.
Pa. Const, art. 1, § 11.
In Ieropoli v. AC&S Corporation, 577 Pa. 138, 842 A.2d 919 (2004), our Supreme Court explained that this provision of Article 1, Section 11 directs the judiciary to administer justice by due course of law and prohibits the legislature from in-termeddling with those judicial functions. Ieropoli, 577 Pa. at 149, 842 A.2d at 925-26 (quoting Menges v. Dentler, 33 Pa. 495 (1859)). The Court went on to explain that the “guarantee of a ‘remedy by due course of law1 in Article 1, Section 11, means that a case cannot be altered, in its ‘substance,’ by subsequent law[.]” Id.
A case is altered in its “substance” once legislation affects a “cause of action” that has “accrued.” Lewis v. Pennsylvania Railroad Co., 220 Pa. 317, 69 A. 821 (1908) (stating that “the law of the case at that time when it became complete is an inherent element in it; and, if changed or annulled, the law is annulled, justice denied, and the due course of law is violated”). A “cause of action” is “the vehicle by which a person secures redress from another person for the consequences of an event that is a legal injury.” Ieropoli, 577 Pa. at 155, 842 A.2d at 929-30. A cause of action does not necessarily “accrue” the day the lawsuit is filed; instead, it accrues once a potential plaintiff has an existing right to sue. See, e.g., New York & Pennsylvania Co. v. New York Cent. R.R. Co., 300 Pa. 242, 150 A. 480 (1930). An “accrued” cause of action, in turn, creates a vested right, the interference with which by the legislature is a violation of Article 1, Section 11. Gibson v. Commonwealth, 490 Pa. 156, 415 A.2d 80 (1980) (quoting Lewis, 220 Pa. at 319, 69 A. at 823) (stating that “ ‘[tjhere is a vested right in an accrued cause of action.... A law can be repealed by the law giver; but the rights which have been acquired under it, while it was in force, do not thereby cease. It would be an absolute injustice to abolish with the law all the effects it had produced. This is a principle of general jurisprudence; but a right to be within its protection must be a vested right.’ ”).
Our cases clearly demonstrate that the General Assembly cannot pass legislation that retroactively affects a cause of action that has already accrued. For instance, in Jenkins v. Hospital of Medical College of Pennsylvania, 535 Pa. 252, 634 A.2d 1099 (1993), the plaintiff brought an action against her medical providers for negligence and for wrongful birth, a cause of action that was recognized at common law. Four years later while the case was ongoing, the General Assembly passed a statute (42 Pa.C.S. § 8305) that precluded any cause of action for wrongful birth for any case pending or on appeal as of the statute’s effective date, which included the plaintiffs case. Our Supreme Court held that Section 8305 could not operate to dismiss plaintiffs’ wrongful birth claims because she had a vested right in the cause of action that commenced before Section 8305 was passed and given retroactive effect. See also Rebel v. Standard Sanitary Mfg. Co., 340 Pa. 313, 318-19, 16 A.2d 534, *361537 (1940) (plaintiffs claim for injury sustained at work, alleging violation of statute giving injured workers a cause of action for negligence against employers, could not be affected by subsequent repeal of that statute; “in Kay v. Pennsylvania Railroad Co., 65 Pa. 269, 277, 3 Am. Rep. 628, it was said: ‘The law of the case at the time when it became complete is an inherent element in it, and if changed or annulled the right is annulled, justice is denied, and the due course of law violated.’ ”).
In Gibson, plaintiffs filed five separate actions in trespass between July and October 1978 against the Department of Environmental Resources and the Commonwealth, alleging that they negligently supervised the dam that caused a flood during a heavy rainstorm in 1977. At that time, sovereign immunity did not exist. Thereafter, the General Assembly passed Act 152, which created statutory sovereign immunity for the first time in Pennsylvania. Based on Act 152, the commonwealth parties argued that plaintiffs’ claims were barred by sovereign immunity because the language of Act 152 applied retroactively and applied to plaintiffs’ cause of action. Our Supreme Court held that Act 152 could not apply because no sovereign immunity existed at the time the plaintiffs’ cause of action accrued, which was nearly a year before the General Assembly passed Act 152.
Finally, our Superior Court in Stroback v. Camaioni, 449 Pa.Super. 395, 674 A.2d 257 (1996), held that a motorist injured in March 1990 seeking to recover medical expenses that were precluded from recovery by the General Assembly three months after the accident could not be foreclosed by doing so by that subsequent legislation. The court explained as follows:
Under the version of Section 1722 in effect on March 15, 1990, the day that appellee’s cause of action arose, appellee was entitled to recover all medical expenses, in excess of the required $10,000 in medical coverages, which she had, or would in the future, incur as a result of the accident, irrespective of whether those medical bills had been paid by a person, plan, or company other than ap-pellee. See, e.g.: Palmosina v. Laidlaw Transit Company, Inc., 445 Pa.Super. 121, 664 A.2d 1038 (1995).... Thus, ap-pellee was entitled, as of the day her cause of action arose, to seek recovery of all of her subsequently incurred medical bills which exceeded $10,000. This was a substantive right which could not properly be revoked by subsequent legislative action. See, e.g., Jenkins v. Hospital of The Medical College of Pennsylvania, 401 Pa.Super. 604, 616-17, 585 A.2d 1091, 1096-97 (1991), aff'd., 535 Pa. 252, 634 A.2d 1099 (1993); Bell v. Koppers Co., Inc., [481 Pa.] supra [454] at 458-59, 392 A.2d [1380] at 1382; Byard F. Brogan, Inc. v. Workmen’s Compensation Appeal Board, 161 Pa.Cmwlth. 453, 462-63, 637 A.2d 689, 694 (1994). Cf. Lynn v. Prudential Property and Casualty Insurance Co., 422 Pa.Super. 479, 619 A.2d 779 (1993) (statute providing for peer review organization review was procedural rather than substantive and, thus, could be applied to medical bills payable pursuant to contracts entered into prior to effective date of statute).
However, as a result of the Act 6 amendments effective July 1, 1990, the right to recover such excess medical expenses was extinguished where those expenses were paid by any entity identified in the amended Section 1722. We concur in the conclusion of the trial court that the amended statute could be applied only to bills arising from accidents occurring after July 1, 1990, and was inapplicable in the instant case *362where appellee had a substantive right as of March 15, 1990, to pursue a claim for excess medical expenses which could not later be extinguished by the enactment of the legislation known as Act 6. It is well-settled that the Legislature may not extinguish a right of action which has already accrued to a claimant.
Id. at 261.
The chronology of events in all these cases can be summarized as follows: (1) a legitimate cause of action ensued; (2) before the cause of action ended, the General Assembly enacted legislation that either retroactively eliminated the cause of action altogether or affected the law in force at the time the action arose; and (8) the retroactive legislation was either invalidated as running afoul of Article 1, Section 11 or held not to apply to the commenced cause of action. Importantly, the underlying theme in all of these eases is that there was something systemically and inherently wrong with a state legislature interfering with a cause of action that had commenced. As those cases illustrate, a cause of action is a snapshot of the facts and law that exist at the time the controversy began until the time it finally ceases. It must be viewed in a legal “bubble” and decided based on the law and the facts as they existed at the time the lawsuit commenced without interference by subsequent acts of the General Assembly. Should the legislature interfere with accrued causes of action, then the legislature, not the judiciary, becomes the arbiter of private disputes.
Applying the general principles of Ieropoli and its progeny here should lead to the result that the retroactive application of Act 20 runs afoul of Article 1, Section 11. As a general proposition, once Koni-daris filed the lawsuit to recover improperly charged fees and to prevent the attempted collection of those fees in the future, the legislature was effectively prohibited from intermeddling with the “substance” of that lawsuit. Ieropoli. In other words, on January 17, 2003, when Portnoff imposed attorneys’ fees that were not authorized under the Tax Lien Law at that time, Konidaris had an “accrued cause of action” against Portnoff to recover those fees and to prevent the attempted collection of those fees in the future, whether or not the Konidaris lawsuit was actually filed on that date or two months later. Id; see also New York & Pennsylvania Co.
The chronology of this case, furthermore, mirrors the chronology of the cases that have struck down retroactive legislation in violation of Article 1, Section 11. The Tax Lien Law as it existed when the Tax Claims against the Konidaris Property began had no provision granting the authority to municipalities, school districts, or their agents to recover attorneys’ fees in connection with the collection of delinquent taxes. This is not disputed by the parties. Roughly ten days later, Konidaris filed a class-action complaint against Port-noff to preclude it from attempting to recover attorneys’ fees in connection with the collection of the delinquent taxes under our Supreme Court’s decision in Pentlong and to recover improperly collected attorneys’ fees by Portnoff. Pour months later, while the Konidaris lawsuit was pending, Act 20 was enacted and signed into law by the Governor, which purported to give municipalities and school districts (and their agents) the authority to collect attorneys’ fees retroactive to tax claims beginning in 1996, which included the Konidaris Tax Claim. It is absolutely clear by the chronology of this case that Act 20 immediately affected the Konidaris cause of action that had already ensued in violation of Article 1, Section 11.
*363While I agree with the majority that a cause of action accrued for fees “actually recovered” by Portnoff before the passage of Act 20, I disagree with the majority’s implication that Konidaris cannot prevent Portnoff from recovering any fees not “actually received” before the passage of Act 20. The majority reaches this conclusion by essentially defining “cause of action” as “counts in the complaint” for purposes of Article 1, Section 11. The majority’s count-by-count approach at defining the Konidaris lawsuit ignores the notion that the “cause of action” was the wrongful attempt to collect unauthorized attorneys’ fees for delinquent taxes, not the counts of the complaint which were merely the vehicle by which to enforce legal rights and to pursue legal remedies. For purposes of Article 1, Section 11, however, it is enough to say that the moment a cognizable legal injury is befallen a potential plaintiff, whatever that injury may be, a cause of action has “accrued” and cannot be subsequently eliminated or altered by retroactive act of the legislature. As illustrated above, the cause of action in this case was the right to recover fees and prevent the future attempt to collect fees on underlying tax claims that no one had the authority to impose in the first place as of the day the liens arose, whether or not those fees were “actually received” by Portnoff.
Finally, I disagree with the majority that the declaratory judgment action should have been dismissed for lack of service on the District (or any of the other taxing authorities) because it is not an indispensable party. Konidaris and other similarly situated plaintiffs challenged the propriety of the underlying lien which has to do with the collection of unlawfully imposed fees (ancillary to the actual tax) by a third party, rendering service on the taxing authority immaterial. It would be a different matter had the Konidaris lawsuit alleged that the underlying tax was improper, miscalculated, or that the amount of the fee levied was improper. It appears from the complaint that once the District decided to either sell the liens to a third party or authorized an outside agent such as Portnoff to collect the liens, like any buyer of bad debt or collection agency, it received the illegal fees directly and became the real party in interest. Consequently, because the District is not the real party in interest, service on the District was neither necessary nor a proper basis to dismiss the declaratory judgment portion of Konidaris complaint. In any event, failure to serve the District and dismiss it from the case because it was an indispensable party was not a basis upon which summary judgment was sought and upon which the trial court granted summary judgment in favor of Portnoff.
In light of the foregoing, I would (1) hold that Act 20 is unconstitutional retroactive legislation insofar as it applies to causes of action for recovery of attorneys’ fees that have accrued before the date of enactment; (2) hold that Act 20 is constitutional insofar as it is applied prospectively to the collection of tax hens arising after the date of its enactment; and (3) enter summary judgment in favor of Konidaris and, if the action is certified as a class action, other similarly situated plaintiffs.
President Judge COLINS and Judge FRIEDMAN join in this dissenting opinion.