Washington State Housing Finance Commission v. O'Brien

671 P.2d 247, 100 Wash. 2d 491
CourtWashington Supreme Court
DecidedOctober 28, 1983
Docket49739-7
StatusPublished
Cited by17 cases

This text of 671 P.2d 247 (Washington State Housing Finance Commission v. O'Brien) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Washington State Housing Finance Commission v. O'Brien, 671 P.2d 247, 100 Wash. 2d 491 (Wash. 1983).

Opinions

Dimmick, J.

Does the authority granted by the Legislature to the Washington State Housing Finance Commission violate the Washington State Constitution which prohibits [493]*493lending of the state's credit? We find that it does not.

The Legislature created the Commission after investigating the impact of Washington's severe economic recession on the state's housing needs. It found that the sustained high interest rate in the mortgage market precluded home buying for many low to middle income families. The ramifications from the stagnate housing market were numerous. Home construction was at record lows, and current housing supply was critically below the population's needs, for both home buyers and renters. Many persons unable to procure financing to buy homes were forced into the rental market. With rental housing in high demand, low income units became difficult to find. Increasingly, substandard housing became occupied.

Recognizing both the housing need and the downward spiral effect on the state's economy if the housing situation were not remedied, the Legislature established a home mortgage program. Laws of 1983, ch. 161. Program funds are to be generated from the Commission's issuance of nonrecourse tax-exempt revenue bonds pursuant to federal law.1 Using bond proceeds, the Commission is authorized to invest in, purchase, or make commitments to purchase home mortgages to provide "decent, safe, sanitary, and affordable housing for eligible persons". Laws of 1983, ch. 161, § 5, p. 697. Payments made on such loans will be remitted to the Commission's trustee bank by the lender. All payments, along with bond proceeds, are held in trust for the benefit of bondholders.

To commence the program, the Commission adopted two resolutions on August 3, 1983. The first authorized the issuance of revenue bonds for mortgage aid to first-time home buyers. The second resolution authorized revenue bonds to aid mortgagors of qualified multifamily residential [494]*494housing. The chairman and secretary refused to sign the resolutions after being advised that they might be unconstitutional. The Commission thereupon brought this mandamus action to compel their signatures on both resolutions. We find the petition meritorious and grant the writ.

Although the course of decisions under the Washington Constitution's lending of credit prohibition2 has not been smooth, this court has firmly rejected, as violations of the clause, any legislative appropriation of tax revenues at the solicitation of private enterprise to aid or subsidize private commercial ventures. See, e.g., State Hwy. Comm'n v. Pacific Northwest Bell Tel. Co., 59 Wn.2d 216, 367 P.2d 605 (1961); Johns v. Wadsworth, 80 Wash. 352, 141 P. 892 (1914). At the time of our constitutional convention, fear of powerful corporate entities was uppermost in the minds of the convention members. The disastrous consequences to taxpayers as a result of corporate political clout were well known. Knapp, The Origin of the Constitution of the State of Washington, 4 Wash. Hist. Q. 227, 239-40 (1913). The concern of the constitutional convention was "protection of [the] weak from the strong within." Journal of the Washington State Constitutional Convention, 1889, at 682 (B. Rosenow ed. 1962). The constitutional framers believed that government was not instituted to confiscate private property through taxation tó enhance corporate profit. Journal. Nor did they consider it proper for the State to put taxpayers at undeterminable risk by pledging future tax revenues for private benefit. See Knapp, at 270-71.

In the past we did not distinguish whether tax revenues or the state's status was used to confer a benefit. See, e.g., Washington Health Care Facilities Auth. v. Ray, 93 Wn.2d 108, 605 P.2d 1260 (1980). Recently, however, we have focused primarily on the risk that the state program [495]*495posed to the public treasury or taxpayer. In re Marriage of Johnson, 96 Wn.2d 255, 634 P.2d 877 (1981). In doing so, we recognized that the constitutional convention did not intend to hinder state government from carrying out its essential function to secure the health and welfare of the state's citizens. In re Marriage of Johnson, 96 Wn.2d 255, 634 P.2d 877 (1981); Rauch v. Chapman, 16 Wash. 568, 48 P. 253 (1897). Certainly, the lending of credit clause was not intended to insulate taxpayers from all risk and debt accruing from the public decisions of their governing representatives. Risk flowing from public ventures legitimately undertaken is inherent in our form of government. The difficulty underlying the lending of credit decisions is making the distinction between proper risk to the taxpayer from public decisionmaking, and improper risk to taxpayers due to abdication of public control over the state's assets or status to private commercial decisionmaking.

The "risk of loss" approach requires us to evaluate whether the state program "has safeguards absent in the schemes of the nineteenth century." In re Marriage of Johnson, supra at 268. The safeguards must ensure that "[t]he public controls both the use of the State conferred 'asset' and the extent of its liability." In re Marriage of Johnson, supra at 268. The State must also retain the means to effectuate the project's public objective. Because these safeguards are central to the lending of credit clause, we now extend the same inquiry to state projects financed by nonrecourse revenue bonds.

We are satisfied that the Commission's authority meets these criteria. The primary purpose of the Commission's program is not to enhance the private sector's profit at the taxpayer's expense, but rather to make decent housing available statewide.3 In determining legislative motive, we [496]*496give great weight to the statutory declaration of purpose. Public Empl. Relations Comm'n v. Kennewick, 99 Wn.2d 832, 664 P.2d 1240 (1983). While a legislative declaration does not conclusively establish its legitimacy, we accept the declaration unless it is shown to be arbitrary or unreasonable. The facts in the present controversy indicate that the legislative purpose, to rectify state housing deficiencies, is eminently reasonable.

The Legislature had before it studies and testimony on the state's economy and the housing market. From these they reasonably concluded that a public problem existed requiring state action. Uncontroverted testimony indicated that a significant portion of the state's population was inadequately housed. Further, it was apparent that the private sector had been unable to correct the housing scarcity resulting from continuing high interest rates and escalating construction costs.

The adequacy of private housing and the health of the state's economy have traditionally been concerns of state government. See, e.g., Housing Auth. v. Seattle,

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Washington State Housing Finance Commission v. O'Brien
671 P.2d 247 (Washington Supreme Court, 1983)

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Bluebook (online)
671 P.2d 247, 100 Wash. 2d 491, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-state-housing-finance-commission-v-obrien-wash-1983.