PSEA v. PSERB (majority)
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In this appeal, the Pennsylvania State Education Association (PSEA) challenged a resolution issued by the Public School Employees’ Retirement Board (PSERB), which addressed how it intended to apply a statute related to the withdrawal of public school employees from a multi-employer pension system. The Commonwealth Court dismissed PSEA’s action for lack of standing. The court held that PSEA had not shown a substantial, direct, and immediate interest in PSERB’s action or inaction, as PSEA's true dispute was with school district employers over subcontracting, not with PSERB.
However, the Supreme Court of Pennsylvania reversed this decision, finding that PSEA did have standing to challenge the resolution. The Supreme Court held that PSEA’s interest in the issue was substantial as it far exceeded the interest of the public at large in the correct application of the statute. The court also found that PSEA’s interest was direct because the resolution was causally connected to the harm PSEA alleged in its ability to effectively negotiate over subcontracting decisions. Additionally, the court found that PSEA’s interest was immediate because the causal connection was real and concrete, not remote or speculative. The court noted that PSEA's averments established a substantial, direct, and immediate interest sufficient to warrant a request for the sort of remedy that a declaratory judgment action seeks—a clarification of the law to resolve a dispute between interested parties over its meaning. Consequently, the Supreme Court of Pennsylvania reversed the Commonwealth Court’s order and remanded the matter to allow PSEA’s action to proceed.
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