The Pennsylvania Supreme Court has ruled that the Coatesville Area School District should not have been barred from a merits resolution of its appeal of a tax assessment on the bases of res judicata and collateral estoppel.

The case stems from an application for a real estate tax exemption by Huston Properties, which argued that a property it owned in Coatesville was subject to a tax exemption because it was regularly used as an institution of purely public charity, according to the Commonwealth Court's Aug. 7, 2009, opinion. The Chester County Board of Assessment granted a partial exemption of 72% for the 2014 tax year and both the Coatesville Area School District and the city of Coatesville filed separately docketed appeals. The school district then intervened in the city's case and Huston filed cross-appeals in both matters. While the parties agreed to consolidate the dual matters for trial, they were never moved under a common docket number.