Board of Supervisors of Fairfax County v. Massey
Virginia Supreme Court
173 S.E.2d 869 (1970)

- Written by Sean Carroll, JD
Facts
Fairfax County (the county) entered an agreement with other governments in Virginia, Maryland, and the District of Columbia to establish the Washington Metropolitan Area Transit Authority (WMATA). WMATA was designed to provide mass-transit services for the counties and cities subject to the agreement. After the Virginia Supreme Court ruled that the county’s guarantee of WMATA’s operating deficits constituted debt subject to the county’s constitutional debt limitation, the county amended its service agreement with WMATA. Under the new agreement, the county was required to make payments to WMATA pursuant to a formula based on the number of miles of the transit system in the county and the number of county residents who used the system. The county’s payments were conditioned on service being provided, and the county was no longer required to guarantee WMATA’s operating deficits. Despite the amended agreement, the same question was presented to the Virginia Supreme Court of whether the county’s payment obligation constituted a debt subject to its constitutional debt limit. The Board of Supervisors of Fairfax County argued that it did not.
Rule of Law
Issue
Holding and Reasoning (I’Anson, J.)
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