On May 19, 2026, the Pennsylvania Supreme Court issued a landmark decision in Downingtown Area School District v. Chester County Board of Assessment Appeals, resolving the continuing uncertainty surrounding the constitutional standards governing public school district property tax assessment appeals. The case centered on the Pennsylvania Constitution’s Uniformity Clause, which requires that taxes be imposed uniformly upon the same class of property, and has increasingly been invoked to challenge the manner in which taxing districts select properties for assessment appeals. The Court held that a school district may constitutionally utilize a monetary-threshold in identifying underassessed properties to appeal, so long as the policy is facially neutral and not based on impermissible classifications such as property type or ownership category.

In reaching that conclusion, the Court rejected the argument that an appeal program becomes unconstitutional merely because it results in a disproportionate number of commercial property appeals, and clarified that school districts are not required to appeal every underassessed property. The Court recognized that taxing districts must be permitted to adopt administratively practical policies and apply objective financial criteria when determining where to devote limited public resources, and emphasized that the constitutional inquiry focuses on whether the selection of properties to appeal is based on neutral factors and consistently applied in a nondiscriminatory manner. The decision provides significant guidance to school districts statewide and substantially clarifies an area of law that had remained unsettled following prior Supreme Court and Commonwealth Court decisions. School districts should nevertheless continue to review existing assessment appeal policies and practices to ensure that appeal decisions remain grounded in objective, consistently administered standards.

Lamb McErlane partners Scot R. Withers and Mark P. Thompson were the lead attorneys on this case, representing Downingtown Area School District (DASD).