Park 'N Go v. Airport Authority

Summary

The court held that the Airport Authority's charge on off-airport parking companies was an optional user fee, not an unconstitutional tax, because it was imposed only on companies using and benefiting from airport facilities and was reasonably related to airport-generated business. The court declined to adopt a single test for distinguishing taxes from fees and instead required a case-by-case examination of the charge's purpose and circumstances. The district court's declaratory and injunctive judgment was therefore reversed, and the complaint was remanded for dismissal.