Convention Center Authority v. Anzai
Hawaii Supreme Court
890 P.2d 1197 (1995)
The Hawaii legislature authorized $350,000,000 in revenue bonds to construct a convention center. The legislature also increased the state’s transient-accommodation tax (TAT) by 1 percent. The TAT was charged on sales of hotel rooms. Revenue from that 1 percent increase was placed directly into a special revenue fund, the Convention Center Capital and Operations Special Fund (the fund). Revenues from the convention center, once constructed, would also be earmarked for the fund. The fund was to be used to secure the revenue bonds once they were issued. The Hawaii Convention Center Authority (the authority) (plaintiff) asked the state finance office to issue the bonds, but the office’s director (defendant) refused, citing concerns that the bonds would take the state over the state’s constitutionally imposed debt limit. The authority filed for a declaratory judgment that the bonds were exempt from inclusion in the state debt that was subject to the limit. Specifically, the authority argued that the bonds were secured by the TAT, which was a user tax qualifying the bonds for the exemption.
Rule of Law
Holding and Reasoning (Moon, C.J.)
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