Sheehan v. Central Puget Sound Regional Transit Authority

155 Wash. 2d 790 (2005) · Washington Supreme Court · November 10, 2005

Summary

The Washington Supreme Court affirmed summary judgment dismissing challenges to motor vehicle excise taxes imposed by Sound Transit and the Seattle Popular Monorail Authority. The court held that the taxes were authorized by law, valid excise taxes, properly collectible annually, not preempted by Washington vehicle-licensing statutes, and not prohibited property taxes. The court also held that delaying class-certification proceedings until resolution of dispositive motions was permissible and that the class-certification issue was moot.

Holdings

  1. The Authorities' use of vehicle registration as the event triggering their motor vehicle excise taxes was authorized by law and did not violate article VII, section 5 of the Washington Constitution.
  2. The motor vehicle taxes were valid excise taxes rather than unconstitutional property taxes.
  3. The enabling legislation authorized annual imposition and collection of the motor vehicle excise taxes; it did not establish a one-time per-vehicle cap.
  4. The Authorities' ordinances satisfied article VII, section 5 because they identified the transit and monorail projects to which the tax proceeds were dedicated.
  5. RCW 46.08.010 did not preempt the Authorities' motor vehicle excise taxes.
  6. The Authorities' taxes were not ad valorem or property taxes prohibited by RCW 82.44.130 and RCW 84.36.595(2).
  7. The trial court acted within its discretion by deferring the CR 23 class-certification decision until after deciding dispositive motions, and the class-certification issue was moot after dismissal of the substantive claims.

Questions Presented

  1. Whether Sound Transit's and the Monorail's motor vehicle excise taxes violated article VII, section 5 of the Washington Constitution because the enabling statutes did not expressly identify vehicle registration as the taxable event.
  2. Whether the taxes were invalid excise taxes because they were allegedly involuntary or were measured by vehicle value rather than by use of public roadways.
  3. Whether the enabling legislation authorized annual collection of the taxes or instead imposed only a one-time per-vehicle cap.
  4. Whether the taxing ordinances failed to state distinctly the object of the taxes as required by article VII, section 5.
  5. Whether the taxes were preempted by RCW 46.08.010.
  6. Whether the taxes were prohibited property taxes under RCW 82.44.130 and RCW 84.36.595(2).
  7. Whether the trial court abused its discretion by deciding the cross-motions for summary judgment before ruling on the CR 23 class-certification motion.
  8. Whether appellants were entitled to attorney fees.

Disposition

affirmed

Cases Cited (16)

  • Jones v. Allstate Ins. Co., 146 Wn.2d 291, 300, 45 P.3d 1068 (2002)(followed)
  • Okeson v. City of Seattle, 150 Wn.2d 540, 548-49, 78 P.3d 1279 (2003)(followed)
  • State v. J.P., 149 Wn.2d 444, 450, 69 P.3d 318 (2003)(followed)
  • Dep't of Ecology v. Campbell & Gwinn, L.L.C., 146 Wn.2d 1, 9-12, 43 P.3d 4 (2002)(followed)
  • C.J.C. v. Corp. of the Catholic Bishop of Yakima, 138 Wn.2d 699, 708-09, 985 P.2d 262 (1999)(followed)
  • King County v. City of Algona, 101 Wn.2d 789, 791, 681 P.2d 1281 (1984)(followed)
  • Harbour Vill. Apartments v. City of Mukilteo, 139 Wn.2d 604, 611, 989 P.2d 542 (1999)(followed)
  • Black v. State, 67 Wn.2d 97, 99, 406 P.2d 761 (1965)(followed)
  • State ex rel. Hansen v. Salter, 190 Wash. 703, 705-07, 70 P.2d 1056 (1937)(followed)
  • Dep't of Revenue v. Hoppe, 82 Wn.2d 549, 552, 512 P.2d 1094 (1973)(distinguished)

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