Judges: Robert T. Stephan, Attorney General
Filed Date: 8/24/1993
Status: Precedential
Modified Date: 7/5/2016
Mr. Charles F. Speer, Esq. Counsel for Fairfax Drainage District 1700 City Center Square 1100 Main Street Kansas City, Missouri 64105
Dear Mr. Speer:
As counsel for the Fairfax drainage district (hereinafter district) you inquire whether the district may compel the City of Kansas City, Kansas (city) and the Kansas City board of public utilities (BPU) to pay a voluntary user fee for the use of your drainage system.
You indicate that currently all non-municipal entities which are benefited by their use of the system pay for such use through an ad valorem property tax. K.S.A.
In contrast to this current position, the city and the BPU have a long history of cooperation with the neighboring drainage district as evidenced by various agreements and contracts. See Alber v. KansasCity,
Also filed accordingly and the most current evidence of cooperation between the city and the district is an amendment to the above interlocal agreement entitled Amendment No. 1, dated June 18, 1992 where the parties agree to create an advisory body to study problems of mutual concern and where the city agrees to provide additional funds to clean existing sewer lines within the district. Additional financial support subsequent to this last amendment's expiration is the subject of the present contention among the parties.
At issue is whether the district is authorized to charge a fee for the services it provides to the city, absent contractual consent. Conversely, we may address whether the city's property tax exemption also exempts the city from paying fees for services provided by the district. As a creature of statute, the district, a quasi-municipality, has only those powers provided by statute. Thus in order to determine whether the district is authorized to charge the city for its services under the circumstances, we must peruse the statutes creating the district and if necessary, discern legislative intent.
In the interest of brevity, we note that the drainage or sewer charge in question is not a tax or a special assessment. Rather the charge in question is in the nature of a rent or toll paid for services furnished. McQuillin Municipal Corporations sec. 31.30.10 (3rd ed., 1991). Seegenerally State v. Bartos,
Among the powers enumerated in K.S.A.
Additionally the district may, as a taxing subdivision of the state, enter into contracts for the payment of service charges in lieu of taxes. These statutes clearly authorize a fee in return for services rendered when the parties enter into contract. However, they cannot be cited as authorizing the charge or fee in question absent a contract.
The absence of a contract was contemplated by the legislature. K.S.A.
We can find no similar statutory provision authorizing a similar action against a city, although an implied contract argument can be made when a municipality avails itself of a benefit or a service from another municipality. 56 Am.Jur.2d Municipal Corporations, secs. 519, 524 (1971). See Opinion of the Justices,
Contrary to reason but in accordance with the statutes, we must find that the district does not have statutory authority to charge a fee and compel the city and the BPU to pay the same. Although a harsh conclusion, we cannot from the powers enumerated in the district's statutes imply the authority for the sake of convenience. See
McQuillin, Municipal Corporations sec. 10.12 (3rd ed., 1991). However, we must also conclude that we find no authority for the proposition that a property tax exemption also exempts the city from paying for services provided by the district and voluntarily accepted by the municipality.See State Highway Commission v. City of Topeka,
In summation it is evident from the perusal of the statutes empowering drainage districts that the legislature intended the parties in question cooperate for the provision of services and the payment therefor by entering into contract. In the absence of cooperation we must conclude that either litigation based on implied contract for the rendition of a proprietary service to a municipality, or legislative changes are in order. See generally, Drainage District v. Wyandotte County,
Very truly yours,
ROBERT T. STEPHAN Attorney General of Kansas
Guen Easley Assistant Attorney General
RTS:JLM:GE:jm