Warren County Residents v. Industrial Development Authority

57 Va. Cir. 483, 2000 Va. Cir. LEXIS 634
CourtVirginia Circuit Court
DecidedNovember 2, 2000
DocketCase No. (Law) 99-310
StatusPublished

This text of 57 Va. Cir. 483 (Warren County Residents v. Industrial Development Authority) is published on Counsel Stack Legal Research, covering Virginia Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Warren County Residents v. Industrial Development Authority, 57 Va. Cir. 483, 2000 Va. Cir. LEXIS 634 (Va. Super. Ct. 2000).

Opinion

BY JUDGE JOHN E. WETSEL, JR.

This case came before the Court on October 25, 2000, on the Defendant’s Demurrer to the Petition for an Audit and Motion for Summary Judgment on the Petitioners’ claim that the Industrial Development Authority’s acting as a general contractor for the construction of facilities for a new commercial enterprise in Warren County was an ultra vires act. Upon consideration, the Court has decided to sustain the demurrer, because the Authority is a political subdivision of the Commonwealth and is not subject to the audit statute for local governments, and to grant the Authority’s Motion for Summary Judgment, because the Authority did not exceed its lawful powers.

I. Statement of Material Facts

The following material facts are not in dispute.

The Industrial Development Authority of the Town of Front Royal and the County of Warren (hereafter the “Authority”) was created by the Town of Front Royal and Warren County pursuant to the Virginia Industrial Development and Revenue Bond Act. Virginia Code § 15.2-4900 et seq. In 1995 and 1997, the Authority entered into contracts with three corporations [484]*484which were planning to construct new commercial facilities in Warren County. Defendant’s Exhibits C, D, and E. In each instance, the parties to the Agreement were the private corporation, the Authority, the Town, and the County, and the Agreements share certain common features:

a. The Authority conveyed land which was in a Virginia enterprise zone to the private corporation;

b. Each of the private corporations were constructing a new commercial facility on die property being acquired from the Authority;

c. The enterprise was eligible for financial assistance from the Governor’s Opportunity Fund;

d. The Authority was to “serve as the general contractor for the project to purchase and install all construction materials and equipment necessary to equip the Project on a sales and use tax exempt basis....” Ferguson Agreement, Exhibit C, p. 13; and

e. In each agreement, a condition precedent to the Authority’s service as general contractor was the corporation’s obtaining a letter ruling from the Virginia Department of Taxation that the proposed arrangement would be exempt from sales and use taxes.

In each case, the Virginia Department of Taxation issued a letter ruling opining that the proposed format would be exempt. See, e.g. Defendant’s Exhibit B, the Family Dollar Letter Ruling. The three projects were completed, and no sales or use tax was assessed by the Virginia Department of Taxation on any of the three projects.

In 1999, the General Assembly amended Virginia Code § 58.1-609.1 to provide that the governmental exemption for sales and use tax “shall not apply to tangible personal property which is acquired by the Commonwealth or any of its political subdivisions and then transferred to private businesses for their use in a facility or real property improvement to be used by a private entity or for non-governmental purposes....”

The Petitioners are residents of Warren County who have filed the present Petition for an audit of the Authority’s records pursuant to Virginia Code § 15.2-2512 to determine the extent of alleged lost sales and use taxes and seeking the judgment of this Court that the Authority’s general contractor arrangement was an ultra vires act.

[485]*485II. Conclusions of Law

A. Summary Judgment

Summary Judgment is appropriate if there is no material fact genuinely in dispute. Supreme Court Rule 3:18; Carson v. LeBlanc, 245 Va. 135, 139, 427 S.E.2d 189 (1993).

B. Demurrer

In considering a demurrer, the Court must apply “the settled rule that a demurrer admits the truth of all well-pleaded material facts. All reasonable inferences fairly and justly drawn from the facts alleged must be considered in aid of the pleading.” Russo v. White, 241 Va. 23, 24, 400 S.E.2d 160 (1991), quoting Fox v. Custis, 236 Va. 69, 71, 372 S.E.2d 373 (1988). “Upon demurrer, the test of the sufficiency of the motion for judgement is whether it states the essential elements of a cause of action, not whether evidence might be adduced to defeat it.” Lyons v. Grether, 218 Va. 630, 638, 239 S.E.2d 103 (1977). “To justify the Court in sustaining a demurrer to a complaint, the ground of the demurrer must be a short, dry point of law upon which it is clear that the complaint will be dismissed ... at the hearing.” 16 M.J., Demurrer, § 48.

C. Industrial Development Authorities are Political Subdivisions ofthe State

An industrial development authority is “a political subdivision of the Commonwealth with such public and corporate powers” as are set forth in Chapter 49 of title 15.2 of the Code of Virginia. Virginia Code Section 15.2-4903. (Emphasis added.) “A municipal authority created under a municipal authorities act has been regarded as a corporate agency of the state, and not a creature, agent or representative of the municipality organizing it.” 1 McQuillin, Municipal Corporations, § 2.29a (3d ed.). In Chesapeake Devel. Auth. v. Suthers, 208 Va. 51, 56-57, 155 S.E.2d 326 (1967), the Supreme Court held that:

[An industrial development] authority is not the alter ego of the city or county, nor is it a “device or pretense” created to evade constitutional limitations. An industrial development authority is a separate and distinct legal entity established to perform the public purpose designated by the legislature. It is independent of the city [or [486]*486county which created it] in its operations, its incurment of debt, and its ownership of property.

An industrial development authority is a political subdivision of the Commonwealth separate from a county or city. Mayor v. Industrial Devel. Auth., 221 Va. 865, 871, 275 S.E.2d 888 (1981).

Virginia is awash in special districts and authorities like the industrial development authority. As noted in Makielski, The Special District Problem in Virginia, 55 Va. Law Rev. 1182, 1183 (1969), in 1969 there were “300 ‘special districts’ in Virginia, and new ones are added each month. For the fiscal year 1962, special districts accounted for approximately ten percent of all local government expenses....” Of the 300 special districts at that time, twenty-one were industrial development authorities. Id. at 1197. As Professor Makielski noted in his law review article:

There is no completely satisfactory definition of the term special district, and the absence of a good working definition is indicative of its amorphous nature.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Russo v. White
400 S.E.2d 160 (Supreme Court of Virginia, 1991)
Fox v. Custis
372 S.E.2d 373 (Supreme Court of Virginia, 1988)
CARSON BY MEREDITH v. LeBlanc
427 S.E.2d 189 (Supreme Court of Virginia, 1993)
Industrial Development Authority v. La France Cleaners & Laundry Corp.
217 S.E.2d 879 (Supreme Court of Virginia, 1975)
Brown v. Lukhard
330 S.E.2d 84 (Supreme Court of Virginia, 1985)
Town of Crewe v. Marler
319 S.E.2d 748 (Supreme Court of Virginia, 1984)
Industrial Development Authority v. Suthers
155 S.E.2d 326 (Supreme Court of Virginia, 1967)
Lyons v. Grether
239 S.E.2d 103 (Supreme Court of Virginia, 1977)
Makarov v. Commonwealth
228 S.E.2d 573 (Supreme Court of Virginia, 1976)
Kirkpatrick v. Board of Supervisors
136 S.E. 186 (Supreme Court of Virginia, 1926)

Cite This Page — Counsel Stack

Bluebook (online)
57 Va. Cir. 483, 2000 Va. Cir. LEXIS 634, Counsel Stack Legal Research, https://law.counselstack.com/opinion/warren-county-residents-v-industrial-development-authority-vacc-2000.