Upper Bucks County Vocational-Technical School Education Ass'n v. Upper Bucks County Vocational-Technical School Joint Committee

LARSEN, Justice,

dissenting.

I dissent.

The test for determining standing was recently set forth by this Court in Franklin Township, et al. v. Commonwealth of Pennsylvania, et al., 500 Pa. 1, 452 A.2d 718 (1982), where, citing William Penn Parking Garage v. City of Pittsburgh, 464 Pa. 168, 346 A.2d 269 (1975) we confirmed the principle that:

“[T]o have standing, a party must (a) have a substantial interest in the subject matter of the litigation; (b) the interest must be direct; and (c) the interest must be immediate and not a remote consequence.”

In William Penn, supra, we said:

“The core concept, of course, is that a person who is not adversely affected in any way by the matter he seeks to challenge is not ‘aggrieved’ thereby and has no standing to obtain a judicial resolution of his challenge. In particular, it is not sufficient for the person claiming to be ‘aggrieved’ to assert the common interest of all citizens in procuring obedience to the law.”
“It is the latter principle which lies behind the traditional formulation’s requirement that the would-be ‘aggrieved’ party must have an interest which is ‘pecuniary’ and ‘substantial’. Thus, for example, it is clear that some interests will suffice to confer standing even though they are neither pecuniary nor readily translatable into pecuniary terms.”

In particular cases, the standing criteria of Franklin Township and William Penn are relaxed so that judicial review of questionable governmental activity may occur.

“Certain cases exist which grant standing, to taxpayers where their interest arguably does not meet the requirements of William Penn ... The relaxing of those requirements in those cases or, more appropriately, the granting of standing where the degree of causal connec*425tion between the action complained of and the injury alleged is small, can be explained by the policy behind granting taxpayers standing.”
“As [then] Justice Roberts pointed out ... in Faden v. Philadelphia Housing Authority, 424 Pa. 273, 278, 227 A.2d 619, 621-22 (1967).
‘[Although many reasons have been advanced for granting standing to taxpayers, the fundamental reason for granting standing is simply that otherwise a large body of governmental activity would be unchallenged in the courts.’ ”

Application of Biester, 487 Pa. 438, 409 A.2d 848 (1979). I believe the appellees status as taxpayers is sufficient to grant them standing to challenge the legality of the school board’s action in shortening the school year.

Section 1501 of the Public School Code (24 P.S. § 15-1501) provides:

“All public kindergartens, elementary and secondary schools shall be kept open each school year for at least one hundred eighty (180) days of instruction for pupils. No days on which the schools are closed shall be counted as days taught, and no time shall be counted as a pupil session for any activity to which admission is charged. No school district shall be required to change its graduation schedule or require graduating students to return to school after graduation to make up class days lost due to severe weather conditions.... No district which makes a bona fide effort as determined by the Secretary of Education to provide one hundred eighty (180) days of instruction for graduating students shall receive less subsidy payments or reimbursements than it would otherwise be entitled to receive on account of the school year because of the provisions of this section____”

Public School Code of 1949, Act of March 10, 1949, P.L. 30, as amended, 24 P.S. § 15-1501.

The provisions of Section 1501 have been construed to “prescribe as a matter of statewide policy, a mandatory minimum number of days on which schools ‘shall be kept *426open’.” Scanlon v. Mount Union Area Board, 51 Pa. Cmwlth. 83, 415 A.2d 96 (1980).

Turning to the circumstances of this case, following the settlement of a teachers’ strike, the appellant school board scheduled only 164 days of instruction for the 1980-81 school year — sixteen days less than the mandatory minimum prescribed by statute. At trial, there was uncontradicted testimony that the reduced schedule of instruction days would result in a reduction of the school year subsidy of approximately $30,000.00. Although there was no specific evidence that the reduction in the school subsidy would result in a direct pecuniary loss to the appellees in their capacity as taxpayers, I nevertheless would hold that appellees have standing to challenge the school board’s action. The Department of Education chose not to bring an action against the school board for its failure to comply with the 180 day requirement. Additionally, there is slight chance that teenage students or their parents would hire a lawyer to challenge the elimination of sixteen days of instruction.

In cases such as this, public policy favors the granting of standing to taxpayers; otherwise, it is likely that the actions of the appellant school board would become part of that body of governmental activity that would go unchallenged in the courts.

I would affirm the order of the Commonwealth Court.