## Facts

- The Washington Legislature enacted a statute authorizing certain counties, including King County, to finance a new major league baseball stadium using specified taxes and to create a public facilities district (PFD) to own and operate the stadium.
- The King County Council created the Washington State Major League Baseball Stadium Public Facilities District, adopted stadium-financing ordinances, and authorized issuance of $336 million in bonds.
- The financing package relied on dedicated taxes within the sales-and-use tax structure, including incremental taxes related to stadium-area transactions, with revenues pledged to bond repayment.
- The PFD negotiated a lease with the Seattle Mariners requiring, among other obligations: (i) playing at least 90% of home games at the stadium; (ii) a $45 million construction contribution; (iii) profit sharing; (iv) $700,000 annual rent for 20 years; (v) covering certain cost shortfalls; and (vi) insurance, maintenance, and major repairs.
- King County filed an action under a statutory bond-validation procedure seeking a declaratory judgment confirming the validity of the bonds and related financing.
- Taxpayers and intervenor-taxpayers challenged the plan on constitutional and statutory grounds, including claims of an unconstitutional gift of public funds, improper taxation, unconstitutional delegation to the PFD, and the asserted effect of a proposed local initiative imposing stricter county debt limits than state law.

## Issues

1. Whether the stadium financing and lease constituted an unconstitutional gift of public funds to a private entity under the Washington Constitution.
2. Whether the taxes imposed to repay the stadium bonds were constitutionally imposed and lawfully collected.
3. Whether the statute unconstitutionally delegated legislative authority to the public facilities district.
4. Whether a county initiative could impose additional debt limitations that conflict with state-authorized debt and financing for the stadium project.

## Decision

- The Washington Supreme Court affirmed the trial court’s declaratory judgment validating the $336 million bond issue and the associated financing structure.
- The court held the stadium lease and financing did not constitute an unconstitutional gift of public funds because the arrangement served a public purpose and included substantial consideration from the Mariners.
- The court upheld the challenged taxes as constitutionally imposed and properly collected under the legislative scheme authorizing taxes dedicated to stadium financing.
- The court concluded the delegation of authority to the PFD was constitutionally permissible because the Legislature supplied sufficient standards and the PFD functioned as a public entity implementing a defined public project.
- The court held the proposed local initiative was invalid to the extent it attempted to add debt limitations beyond those authorized by state law and thereby obstruct the stadium financing.

## Legal Principles

- A public expenditure that incidentally benefits a private party is not an unconstitutional gift of public funds when it serves a public purpose and the public receives adequate, enforceable consideration that negates donative intent.
- Legislatively authorized taxes dedicated to a specific public project may be upheld when enacted and collected consistently with constitutional requirements and the governing statutory framework.
- Delegation to a public corporation or special-purpose district is permissible when the Legislature provides adequate standards and the entity administers a legislatively defined program rather than exercising open-ended lawmaking power.
- Local initiative power does not extend to measures that conflict with state statutes governing local government debt authority; a county may not impose additional debt limits that effectively negate state-authorized financing.

## Conclusion

The court upheld King County’s stadium bond financing, finding no unconstitutional gift of public funds, sustaining the dedicated tax measures, approving the statutory delegation of authority to the PFD, and rejecting a conflicting county initiative that sought to impose stricter debt limits than state law permitted.


King County v. Taxpayers of King County, 949 P.2d 1260 (Wash. 1997)