City of Philadelphia v. Cumberland County Board of Assessment Appeals

The majority opinion is noteworthy in terms of its scope, thoroughness, and thoughtfulness concerning the creation, history, and sui generis character, of the Girard Trust. I find it persuasive, as well, to the degree it sets forth the basis for considering the Trust to be a Commonwealth entity, and I ultimately agree that the Commonwealth Court’s order should be reversed under the circumstances.

Nevertheless, I cannot join the opinion in full, as I see no reason to depart from this Court’s precedent concerning the scope of tax immunity that a Commonwealth body enjoys. Although, as the…