Biernacki v. Redevelopment Authority’s Empirical Analysis
1977
Citation profile
15 state decisions
How this case has been cited
Cited by 15 later decisions — most recently May 2019
15 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Powell v. Shepard · Tigue v. BASALYGA · Reifsnyder v. Pittsburgh Outdoor Advertising Co. · Commonwealth v. Ambrosia · In Re Condemnation by the Commonwealth
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Although Hart Realty Co., Inc. is the owner in fee of 98 Franklin Street, it is not, and never has been a party to these proceedings. The court below dismissed the Authority’s objection that an indis-pensible party was not joined by simply noting that the Pennsylvania Rules of Civil Procedure do not apply to proceedings under the Eminent Domain Code. While it is true that the Rules of Civil Procedure are not applicable in condemnation cases, the issue of nonjoinder of an indispensible party is not so easily avoided. No court may grant relief in the absence of an indispensible party. An in-dispensible party is one whose rights are so connected with the claims of the litigants that no relief can be granted without infringing upon those rights. As noted, Hart Realty Co., Inc. is, and has been since November 1975, the owner of 98 South Franklin Street. Clearly, the owner of real estate is an indispensible party to proceedings seeking transfer of the title to the property to another and culminating in an order purportedly vesting title in another. It would be difficult to imagine a darker cloud on one’s title than that created by the court’s order in this case. An indispen-sible party not having been joined, the court below was without jurisdiction to grant any relief in this case ...”
2 later decisions quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.