## Facts

- Neighbors in a residential area of Philadelphia sued to stop Siegel from building and operating a public automobile garage and gasoline station near their homes.
- The trial court entered a final decree enjoining the proposed public garage/gas station as a nuisance causing irreparable injury.
- After the injunction, Siegel abandoned the public garage/gas station plan and proposed a narrower use: a building to store automobiles belonging to tenants of nearby apartment buildings he owned.
- Siegel petitioned the trial court to modify the injunction to permit this limited, tenant-oriented storage use.
- The trial court modified the injunction to allow tenant car storage under restrictions preventing operation as a general public garage or gasoline service.
- The neighbors appealed, arguing the original final decree became unchangeable after the appeal period expired and that the modified use should still be enjoined as a nuisance.

## Issues

1. Whether a “final” equity decree granting an injunction may be vacated, modified, or dissolved after the appeal period has expired when circumstances materially change.
2. Whether an automobile storage facility limited to nearby apartment tenants constitutes a nuisance in a residential neighborhood such that it should remain enjoined.

## Decision

- The Supreme Court of Pennsylvania held that injunction decrees are executory and continuing and therefore remain subject to modification, dissolution, or vacation when justice requires, despite being “final” for appeal purposes.
- The court affirmed the modified decree permitting the limited storage of automobiles for nearby apartment tenants, subject to restrictive conditions.
- The court rejected the argument that equity “term” rules or general finality principles barred the trial court from modifying the injunction.

## Legal Principles

- Pennsylvania equity courts have no “terms” that limit the court’s power over injunctive relief in the manner asserted by the plaintiffs.
- While final equity decrees are generally unchangeable after the appeal period (absent a bill of review for gross mistake and absent intervening rights), that general rule does not control decrees that are continuing in character.
- To determine whether later modification is permitted, courts consider whether the decree is final for purposes of execution or instead contemplates ongoing regulation and further judicial action.
- Injunctions are inherently executory and continuing; they regulate ongoing conduct and operate until vacated, modified, or dissolved.
- A material change from a public commercial garage/gasoline station to a restricted facility for tenant automobile storage may justify reshaping injunctive relief, and the limited use is not a nuisance per se when controlled by conditions.

## Conclusion

The court affirmed the trial court’s authority to modify a previously entered injunction because injunctive decrees are continuing orders, and it approved a narrowed, condition-limited automobile storage use for apartment tenants as not warranting the broader prohibition imposed against a public garage and gasoline station.


Ladner v. Siegel, 298 Pa. 487 (1930)