EASTBURN & GRAY, PC Michael E. Peters, Esquire PalD # 314266 Michael T. Pidgeon, Esquire PaID #315147 60 E. Court Street, P.O. Box 1389 Doylestown, PA 18901 215-345-7000 mpeters@eastburgray.com mpidgeon@eastburngray.com ENTERED AND FILED PROTHONOTARY'S OFFICE, LANCASTER, PA *** Electronically Filed*** Jun 15 2018 10:03AM Ricci Deh Attorneys for Plaintiff CI-18-04503 PATRICIA J. KABEL IN THE COURT OF COMMON PLEAS 38 Crestmont Court LANCASTER COUNTY, Lititz, PA 17543 : PENNSYLVANIA Plaintiff, : v. : No. MANHEIM TOWNSHIP : SCHOOL DISTRICT I 450 Candlewyck Road F Lancaster, PA 17606 : Defendant. : COMPLAINT And now, comes Plaintiff, Patricia J. Kabel, by and through her attorneys, EASTBURN & GRAY, PC, Michael E. Peters, Esquire, and Michael T. Pidgeon, Esquire and respectfully sets forth the following Complaint, and in support thereof, avers as follows: 1. Plaintiff Patricia J. Kabel (“Plaintiff”) is an adult individual with an address of 38 Crestmont Court, Lititz, Lancaster County, Pennsylvania, 17543. Plaintiff is currently the elected tax collector for Manheim Township, Lancaster County, Pennsylvania. Plaintiff brings this 6-18-2018 173,25 BD Act 621 $3253 Aergh WeyENTERED AND FILED PROTHONOTARY'S OFFICE LANCASTER, PA ***Electronically Filed*** Jun 15,2018 10:03AM complaint individually, as the elected tax collector for Manheim Township, and as thagigg WARS collector for the Manheim Township School District. 2. Defendant is Manheim Township School District (hereinafter the “District”) a political subdivision and taxing district of the Commonwealth of Pennsylvania, havi g its principal offices at 450 Candlewyck Road, Lancaster, Lancaster County, Pennsylvania, 17606. BACKGROUND oe 3. The District imposes a real estate tax pursuant to the Pennsylvania Public School Code, and is a taxing district for purposes of the Local Tax Collection Law, 72 P.S. § 5511.1, et seq. (hereinafter referred to as the “LTCL”). 4. The District’s territory is limited to Manheim Township. 5. Plaintifffas the elected tax collector for Manheim Township, a political subdivision organized under the First Class Township Code, has the statutory obligation to collect any and all real estate taxes imposed by the District in accordance with the relevant provisions of the LTCL, and the First Class Township Code, and any other applicable provision of Pennsylvania law. See 53 P.S. § 55801-B. 6. Pennsylvania law requires that only Plaintiff, and no other party, is empowered to collect local school real estate taxes within the territorial limits of Manheim Township, unless Plaintiff chooses to appoint a deputy in accordance with 72 P.S. § 5511.22(a)(L).ENTERED AND FILED PROTHONOTARY’S OFFICE LANCASTER, PA **#Electronically Filed*** ; Jun 15 2018 10:03AM 7. At all times relevant, prior to the current collection cycle, real metal Danyes imposed by the District have been collected by the District or its designee, in direct violation of the LTCL and the First Class Township Code, 8. On November 7, 2017, Plaintiff filed a complaint with this Honorable Court, in order to, inter alia, effectuate her collection of District taxes (the “2017 Action”). CI-18-04503 9. The District and Plaintiff agreed, during a conference between counsel and’ the assigned judge in the 2017 Action on May 30, 2018, that Plaintiff will collect real estate taxes for the District henceforth and that the District would provide Plaintiff with all information and materials to effectuate her collection of real estate taxes on behalf of the District. That agreement was memorialized by order of this Court dated June 8, 2018. 10. On May 17, 2018, the District adopted a resolution titled “Resolution Establishing Policies and Procedures for Elected Tax Collectors (the “Procedures”). A true and correct copy of the Procedures are attached hereto as exhibit “A” and incorporated herein. 11, The stated “purpose” of the Procedures is to: (@) give the tax collector options to assist him or her in executing statutory duties in the most time-efficient and least burdensome manner; (b) clearly distinguish between the tax collector’s statutory duties and the tasks that the School District will perform as a result of such tasks not being required of the tax collector under the Local Tax Collection Law; (c) establish policies and procedures for the collection of the School District’s real estate taxes in a manner that will maximize School District tax revenues by ensuring tax receipts and interest earnings are promptly paid over to the School District; and (d) ensure all public tax funds are adequately safeguarded, properly accounted for, and promptly deposited in secure School District bank accounts. [Ex. “A” at p. 1]ENTERED AND FILED PROTHONOTARY'S OFFICE LANCASTER, PA +*** Electronically Filed*** 7 1 18.4.0:03AM 12. The Procedures intrude upon, interfere with, and outright prevent Matai gibi to perform the duties of her elected office. 13. The Procedures deprive Plaintiff of the ability to perform essential activities commensurate with her elected office. 14. The Procedures impermissibly interfere with Plaintiff's office by, inter alia: CI-18-04503 a. Purporting to give the District unrestricted access to the data of the tax collector, including the ability to manipulate the tax collector's data. Procedures §§ 8, 18, 21 b. _ Purporting to deprive the tax collector of the right to provide customer service to taxpayers. Procedures § 9. In fact, the Procedures provide that the tax bills will not include the tax collector's telephone contact information, Procedures § 4. ©. Purporting to require the tax collector to pay over to the School District all taxes collected on a daily basis, without providing sufficient procedures to efffectuate daily transfer (¢.g. to account for checks drawn on nonsufficient funds), or sufficient procedures to protect the integrity of the tax collector's account (eg by allowing the District itself to initiate transactions/withdraws). Procedures §§ 13, 14. 4, _Purporting to establish monetary penalties for untimely tax collector reports, or pay over of funds, where the District’s “remedies” are limited under the LTCL. Procedures §§ 17, 19. 4ENTERED AND FILED PROTHONOTARY’S OFFICE LANCASTER, PA ¥+*Electronically Filed*** . Jun.15 2018 10:03AM ©. Purporting to prohibit the tax collector and permit the Disiter Saaaminyenee offices to issue tax certifications. Procedures § 22. 15. The Procedures are ultra vires, arbitrary, lack a rational basis, and are invalid. 16. The Procedures do not include a severability clause. If this Court determines that, inter alia, the foregoing provisions are invalid, the entire Resolution should be invalidated. CI-18-04503 WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter judgment in favor of Plaintiffs and against Defendant, in the nature of a Declaration that: (1) _ the Procedures impermissibly interfere with Plaintiff s ability to perform the duties of her elected office; (2) the Procedures are invalid; and (3) such other and further relief as this Court may deem just, reasonable and appropriate, COUNT Il -INJUNCTIO! 17. Paragraphs 1 through 16, set forth above, are hereby incorporated as though fully set forth herein, 18. Plaintiff has the statutory and legal obligation to fulfill the duties assigned to the office of tax collector of Manheim Township, a Township of the First Class, including collection of real estate taxes imposed in Manheim Township by the District.ENTERED AND FILED PROTHONOTARY'S OFFICE, LANCASTER, PA. ***Electronically Filed*** . Jun 15 2018 40:03AM 19. The grounds for a permanent injunction are established by demonsttaiiae beb the right to the requested relief is clear; (2) that an injunction is necessary to avoid an injury that cannot be compensated by damages; and (3) that greater injury will result from refusing the injunction than granting the relief requested. Penn Square General Corporation v. County of Lancaster, 936 A.2d 158, 165 (Pa. Commw. Ct. 2007). 20. Plaintiff will continue to suffer irreparable injury, in the form Ofte GsOeSS3 rights and privileges of the office, and the freedom to fulfill her statutory obligations, in the absence of the requested injunction, Plaintiff's injury cannot be remedied by damages. 21. Greater injury will result from refusing the injunction than granting the relief requested, as the Procedures are illegal, ulira vires, and in direct violation of the LTCL, the First Class Township Code, and the requirements set forth by the Supreme Court. 22. Plaintii’s right to relief is clear, as the Regulations are directly contrary to state law, as interpreted by the Courts of this Commonwealth, are ultra vires, arbitrary, lack a rational basis, and are invalid. WHEREFORE, Plaintiff respectfully requests that this Honorable Court issue a permanent injunction as follows: (1) the District is prohibited from enforcing the Procedures; (2) the District shall not interfere with Plaintiff's duty and right to collect District real estate taxes in Manheim Township; andDated: ENTERED AND FILED PROTHONOTARY'S OFFICE LANCASTER, PA ***Electronically Filed*** Jun 45 2018 40:03AM (3) such other and further relief that this Court deems just and necessaty angQBer SRntte under the circumstances, Sune 14, 2018 Respectfully submitted, EASTBURN & GRAY, PC Michael E. Peters, Esquire Pa ID # 314266 Michael T. Pidgeon, Esquire PaID #315147 60 E. Court Street Doylestown, PA 18901 215-345-7000 Mpeters@eastburngray.com mpidgeon@eastburngray.com Attorneys for PlaintiffsENTERED AND FILED PROTHONOTARY’S OFFICE, LANCASTER, PA ***Electronicaily Filed*** VERIFICATION Jun 15 2018 10:03AM Ricci Deh J, PATRICIA J. KABEL, verify that I have knowledge of the facts set forth in the foregoing pleading, and that the statements made therein are true and correct to the best of my Knowledge, information and belief. I understand that if any of my statements herein are false, 1 am subject to the penalties set forth in 18 Pa. C.S. Section 4904, relating to unswomn falsification to authorities. Dated: af L UEENTERED AND FILED PROTHONOTARY’S OFFICE LANCASTER, PA **#Electronicaily Filed*** Jun 15 2018 10:03AM Ricci Deh CI-18-04503 EXHIBIT "AENTERED AND FILED PROTHONOTARY'S OFFICE LANCASTER, PA **Electronically Filed*** Jun 15,2048 10:03AM Ricci Dent MANHEIM TOWNSHIP SCHOOL DISTRICT. ‘Resolution Establishing Policies and Procedures for Elected Tax Collectors Background. For many years, the School District has had no elected real estate tax collector or has hhad an elected realestate tax collector who has voluntarily abdicated bis or her responsibilities tothe School District. Recently, the School District was notified that the elected tax collector who is ‘curzently in office by virtue of firstbeing elected in 2013 and then again in 2017 now wishes to begin collecting the tax beginning with the 2018-2019 fiscal year. CI-18-04503 Under the Local Tax Collection Law, a tax collector elected io collect the School Districts tax has the following statutory obligations: (a) to obtain the proper certification (72 P.S. § 5511.41}; (b) to obtain abond (72.8. § 5511.4); (6) to appointa deputy to serve in the event the tax collector becomes incapacitated (72 P.S. § 5511.22); (@) to maintain office hours (72 P.S. § $511.13); (e) to mail tax bills and certain notices to taxpayers (72 PS, §§ 5511.6 and 5511.10); (f) to pay over to the Scio! District all taxes that the tax collector receives (72 PS. §§ 5511.Sb and 5511.25); (g) to maintain records of tax collections (72 P.S, § $511.40); (h) to issue payment receipts under certain circumstances (72 P.S. § 5511.14); i) (o provide periodic reports to the School District (72 P.S. § 5511.25); @) to settle the duplicate on an annual basis (72 B.S. § 5511.26). ‘The purposes of this Resolution are to: (a) give the tax collector options to assist him or her in executing statutory duties in the most time-efficient and least burdensome manner, (b) cleatly distinguish between the tax collector's statutory’duties and the tasks that the School District will perform as a result of such tasks not being required ofthe tax collector under the Local Tax Collection. Law; (¢) establish policies and procedures for the collection of the School District's real estate taxes in a manner that will maximize School District tax revenues by ensuring tex receipts and interest earnings are promptly paid over to the School Distict; and (@) ensure all public tax. funds are adequately safeguarded, properly accounted for, and promptly deposited in secure School District bank accounts, RESOLVED, by the Board of School Directors, that the following are adopted as policies of the ‘School District applicable to elected tax collectors who choose fo collect tax: Ll Qualified Tax Collector Certification, All tax collectors are required to be “qualified tax collectors” under the program administered by the Pennsylvania Department of Community and Economic Development. 2, Minimum Legal Requirements. On or before May 21, 2018, the tax collector elected during ‘te 2017 general election the “Incumbent Collector”) shall: (a) Provide evidence satisfactory tothe ‘School District of having given the required oath, (b) Provide evidence satisfactory to the School District of having given the required bond. (c) Provide evidence satisfactory to the School District of possession of a Qualified Tax Collector Certificate, criminal history background information report, ‘and appointment of a deputy. (2) Unless the tax collector exercises her option to have tax funds deposited into a School Disttct account as provided below, provide evidence satisfactory to the ‘School District that the tax collector has opened a depository trust account that complies with all applicable requirements set forth under 72 P.S. § 5S11.Sb. For any tax collector other than theENTERED AND FILED PROTHONOTARY’S OFFICE LANCASTER, PA Ricci Dehl Incumbent Collector, the collector shall meet all of the requirements listed in tis paragraph prior to the first calendar year of any new term of office. a 3. The tax collector will maintain office hours in accordance with 72 PS. § ‘5511.13 and as otherwise deemed necessary and appropriate by the School District. The tax collector shall collect the Schoo! District's tax using the office space designated and provided by Manheim ‘Township to collect the Township's tax. If for some reason Manheim Township chooses to no longer provide office space to the tax collector, he or she will use space designated by the. School Distict to collect the School District’ tax. 4, ZaxBills, All wx bills willbe in the form provided by the School District, and @LethBO4503 tax collector office location and hours and, except as otherwise determined by the tax collector as provided below, that tax payment checks will be made payable to the tax collector, 5. TaxDuplicate. On or before July 1 of each year, the School District wil: (a) provide the tax collector with the tax duplicate for real estate taxes; (b) have all tax bills printed and prepared; and © deliver the bills with envelopes and postage to the tex collector. The tax collector will be responsible for sorting, stuffing, mailing, and follow-up to ensure the tax bills are paid. However, if the tax collector so chooses, he or she may request that the School District deliver tax bills already sorted and stuffed into envelopes with postage. ‘The tax collector shall mail out all tax bills within the applicable time period set forth under 72 P.S. § 5511.6. ‘The tax collector must provide taxpayer duplicate information to any requesting escrow fund company, and cooperate in establishing arrangements for electronic payment of tax amounts by the company and payment receipt by the tax collector. 6 Interim Tax Bills. Additions to the duplicate may be made during the year after major iraprovements to @ real estate parcel have been. completed. In such event, the School District will have tax bills printed and prepared, and will then deliver the bills with envelopes and postage to the ax collector. The tax collector will be responsible for sorting; stuffing, mailing, and follow-up to ensure the tax bills are paid. However, ifthe tax collector so chooses, he or she may request that the School District deliver interim tax bills already sorted and stuffed into envelopes with postage. 7. Installment Payments, The tax collector will allow taxpayers to pay tax according to the School District's eal estate tax installment payment plan, 8. Tax Collector Records, The tax collector will utilize tax collection software paid for and provided by the School District. Through use ofthat tax software, the tax colleetor shall keep with respect to each real estate parcel an ongoing, real time, and up to date account of all taxes collected, the amount of tex paid by each taxpayer, the property parcel number, the property parcel address, discounts granted and penalties applied, and the date of each payment. At all times, the School District shall have access to the tax collection software and the tax collector will not in any way interfere with such access, 9. Taxpayer Inquiries. Consistent with the School District's long-standing practice. and the fact that The Local Tax Collection Law does not require a tax collector to provide customer service, the tax collector shall direct all taxpayer inquiries concerning School District tax to the School District's Business Office.ENTERED AND FILED PROTHONOTARY’S OFFICE LANCASTER, PA ***Electronicaliy Filed*** Jun 15 2018 10:03AM eben 10. Taxpaver Receipts and Refunds. Upon request, the tax collector shall furnish each taxpayer ‘vpon payment of taxes a receipt providing the date of payment, name of taxpayer, amount of taxes paid, and identification of the related real estate parcel. A separate receipt shall be issued for each real estate parcel. Where payment of taxes is made by mail, receipt shall be required to be furnished only if the taxpayer encloses with the payment a self-addressed and stamped envelope for the retum. of the receipt. Ifthe tax collector finds that a taxpayer has made a duplicate payment ot otherwise ‘overpaid the amount owed, the tax collector shall provide the School District with a completed “refund request” form. Upon receipt of information satisfactory to the School District, the School District will issue and deliver a refund check made payable to the taxpayer in the amount of the verpayment. Che CI-18-04503 11. Credit Card Payments. Should the School District decide to offer credit card payment options to taxpayers the tax collector will provide the necessary payment platform and infrastructure to accept credit card payments both at the collector's office and over the telephone, 12. Unpafd ‘Tax Notices, Within one (1) week following the end of the face/base collection period, the tex collector shall utilize the tax collection software provided by the School District to Prepare a list of each and every taxpayer with an unpaid balance. Upon receipt of the lst, the School Distiict will print and provide the tax collector with a delinquent notice for each taxpayer on the list, along with envelopes and postage. ‘The tax collector will be responsible for sorting, stuffing, and the notices. However, ifthe tax collector so chooses, he or she may request that the School District deliver notices alteady sorted and stuffed into envelopes with postage, ‘The tax collector shall ‘mail outall delinquent notices within two (2) business days of receiving the notices and envelopes from the School District. 13, _ Requirements for Deposit of Tax Funds. Unless the tax collector elects to have tax fands deposited into a School District account as provided below, the tax collector must deposit tax funds ‘with a financial institution insured by a federal depository insurance programa and designated by the School District. Unless the tax collector elects to have tax funds deposited into a School District account as provided below, the tax collector shall maintain a trust accovat for the deposit of all School District taxes at a bank at which the School District maintains a bank account. Regardless of whether the tax collector chooses to deposit tax into a rust account that he or she maintains or into an account filed in the School District's name as pravided below, all tax funds collected by the tax collector must bbe deposited on the day of receipt, All funds will be automatically swept from any trust account that the tax collector maintains to a District-owned bank account each evening, 14, __ Payments to School District. Each day, the tax collector shall pay over to the School District. all School District real estate taxes collected. 15, tion for Deposit of Taxpaver Payments Directly to School District Account, If he or she So chooses, the tax collector may deposit all taxpayer payments directly into a bank account designated and controlled by the School District. If the Incumbent Collector wishes to exercise this option, then she shall by May 21, 2018 advise the School District of her desire to do so and, if so, whether she wants tax bills to state that tax payment checks should be made payable to the tax collector or to the School District. For any tax collector other than the Incumbent Collector, the collector shall have until November 30 of the year during which he or she is elected to send the School District notice that the collector wants taxpayer payments to be made directly into a bank aocount designated and controlled by the School Distict an, if $0, to also notify the School District whether 3.ENTERED AND FILED PROTHONOTARY’S OFFICE LANCASTER, PA Electronically Filed*** Jun 15 2018 10:03AM (elF dent he or she wants tax bills to state that tax payment checks should be made payable to the tax collector oF tothe School District. If any tax collector elects to have tax payments deposited directly into a School District account, the following terms and conditions will apply: (a) The School District will ‘open a separate bank account for deposit of tax funds collected by the tax collector, and will provide the tax collector with deposit slips. (b) If required by the bank, the tax collector must endorse any tax payment checks made payable to the collector such that the checks can be deposited into the School District account. 16. Interest Famings on Tax Funds. Any interest eamed by the tax collector on tax funds belongs to the School District, not to the tax collector, and the tax collector shall pay of interest to the School District within one (1) business day after the tax collector reaviverok ad the financial institution for such interest. 4503 17. Interest Payable by the Tax Collector on Funds Paid Late, Ifthe tax collector fails to pay ‘over any tax funds or interest by the deadline provided in this Resolution, then the tax collector shail pay to the School District interest at the rate of 6% per annum from the date that the amount was payable until the date of payment to the School District, with such interest to be prorated on the basis of a 365 day year. 18, Tax Collector Reports. The tax collector will use the District-issued tax collection software to record tax payment activity. In addition, the tax collector shall, prior to noon on Friday of each ‘week, make and deliver to the School District a written statement in form satisfactory to the School Distriot reporting all taxes collected through and including the Thursday preceding the date of the report. The zeport shall include the name of each taxpayer, the property parcel nuunber, the property parcel address, the date of payment by each taxpayer, the amount collected from each taxpayer, along ‘ith discounts and penalties applied, if any, and the total amount of taxes received from all taxpayers and diseounts and penalties applied since the last report. The report shall be reconciled with the tex duplicate to show the amount of taxes remaining to be collected. The report shall also include any interest eredited to the tax collector on the tax funds. The report shall further include a listing of any instances of non-compliance with this Resolution that the tax collector is aware of and that were not previously reported in writing to the School District, « narrative explanation of how each such instance ‘of non-compliance came about, and a narrative explanation of how the tax collector has resolved or {is in the process of resolving each such instance of non-compliance. In the event the tax collector has ino instances of non-compliance to report, the tax collector shal certify in the weekly report that there are no'such instances. Each weekly report submitted by the tax collector shall be certified as true and ‘conrect under penalty pursuant to 18 Pa.C.S.A. § 4904 for making any false statements. ‘The format of the tax collector's weekly reporting form is subject to approval by the School District, Any iepott that is not submitted in a format expressly approved by the School District shall be considered delinquent, 19. Penalty for Delinquent Report, I «tax collector does not provide a required report within ‘the required time period, th tax collector shall pay to the School District a fee of twenty dollars ($20) for each day ot part of a day, excluding Saturdays, Sundays, and holidays, for the first six (6) days (hat a report is overdue; and the fee shall be ten dollars ($10) for each day or part of a day, excluding ‘Saturdays, Sundays, and holidays, for each day after the 6 day that a report is overdue. A'delinguent eport shall not be considered fled until all fees owed for ate reporting have also been paid.ENTERED AND FILED PROTHONOTARY’S OFFICE LANCASTER, PA **4Blectronically Filed*** Jun 14.3948 10:03AM Ricci Dehl 20. Kinal Settlement. The tax collector shall make final settlement of the tax duplicate with the ‘School District's Business Office on or before January 2 of each year for the prior calendar year (or if such day is a Saturday, Sunday, or holiday, the next day which is not a Saturday, Sunday, or holiday), 21. Access to Tax Collector Books and Records, Books and accounts of the tax collector shall bbe open to inspection by the Schoo! District or its auditors at any time upon request by the School District. The records, periodic reports, and final account of the tax collector shall be audited by the ‘School District's auditors, ‘The tax collector shall comply in all materiel respects with the requests and directives of the School District's auditors CI-18-04503 22. Tax Certifications. For the following reasons, the School District, not the tax collector, will provide certifications as (0 taxes due or paid: (a) the Schoo! District, not the tax collector, is the ukimate recipient of the tax and is thus the proper party to issue certifications; (b) the tax collector ust use software provided by and fully-accessible to the School District to maintain a real time record of tax receipts, meaning there will be no discernible lapse in time between payment and notice to the School District of payment that would justify imposing the added burden on the tax collector to issue cettifications; (c) the tax collector must deposit all tax on the day of receipt for immediate ‘sweep into a School District account, and there will thus be no material lapse in time between deposit and District receipt that would justify imposing the added burden on the tax collector to issue certifications; and (@) nothing in the Local Tax Collection Law states that providing certifications is a statutory obligation of elected tax collectors 23. Payment of Compensation and Reimbursement of Expenses to Tax Collector. Payment ‘of tax collector compensation will be made on the next payroll after the detailed collections are reported to the School District, Detailed collections are needed to verify the accurate number of bills, collected to process payment. A schedule of the deadline for paperwork for each associated payroll ZOnHnamA ZOmHAOeD w The information collected on this form is used solely for court administration purposes. For Prothonotary Use Docket No: ENTERED AND FILED PROTHONOTARY’S OFFICE ‘Only: **4Electrpnically Filed*** 2018:10:03AM icci Debt"? ;, This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. ‘Commencement of Action: TE Complaint Ey Transfer from Another Jurisdiction Di Writ of Summons C1 Petition 1) Declaration of Taking Lead Plaintiff's Name: Lead Defendant's Name: Tricia Kabel Manheim Township School District Dollar Amount Requested: CABO Ahits Are money damages requested? E] Yes] No heck ne) ouside arbivation init Is this a Class Action Suit? C1Yes No | IsthisanMDJAppeal? (ClYes [No Name of Plaintiff Appellant's Attomey: Michael E. Peters, Esquire 1 Check here if you have no attorney (are a Self-Represented [Pro Se} Litigant) Nature of the Case: Place an “X” to the left of the ONE case category that most accurately describes your PRIMARY CASE. 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