Clay v. Independent School District No. 1 of Tulsa County

OP ALA, Justice,

dissenting.

The court today (a) narrows the teachings of Board of County Commissioners v. City of Muskogee1 (which holds that when there is a statute-imposed duty to pay revaluation costs, a writ ordering the payment of these delinquent costs represents a sinking fund obligation which may be satisfied either out of surplus revenues in that fund or from three annual levies);2 (b) transforms an ad valorem tax recipient’s statutory obligation to pay its share of revaluation costs into a fictitious quasi-contractual debt that may be defeated by failure to include revaluation costs in an obligor’s annual budget request; (c) constricts the availability of mandamus as a remedy against recalcitrant statutory obli-gors of revaluation costs; (d) gives its pro*309nouncement purely prospective effect,3 which makes these obligor-school districts, who failed to include revaluation costs in their 1992-1993 budget, stand subject to this court’s extant Muskogee teachings and (e) remands this cause for further proceedings.

I must recede from today’s pronouncement. The court’s opinion (a) exonerates derelict school district officials from amenability to any civil remedy for their failure, however deliberate, to include the statutorily mandated revaluation obligation of the school district in the annual county budget and (b) impermissibly shifts this statutory responsibility to county officials. The court’s approach enjoins upon county officers the task of protecting the county from continued official school districts’ lawlessness by waging never-ending litigation that is needed to enforce a recipient’s cost-inclusion duty. Because this solution cannot absolutely assure timely and effective collection of delinquent revaluation costs, which are un-budgeted, the county government will be condemned to absorb the entire cost and then pass the loss on to the taxpayers (a) by increasing the next year’s assessments for added revenues or (b) by curbing services to the taxpayer. My analysis for the controversy’s settlement would (a) reaffirm all the teachings of Muskogee, (b) leave in place the district court’s mandamus order, (c) allow its enforcement by resort to the school districts’ sinking funds and (d) strictly enforce against offending school district officials the penalty provisions of the Ad Valorem Tax Code4 whenever the obligor district’s dereliction (by nonfeasance) is judicially found to have been inexcusable.

I

THE CONSEQUENCES OF TODAY’S PRONOUNCEMENT

Without any semblance of authority in extant constitutional jurisprudence, today’s opinion nullifies well-settled legislative power to impose upon a political subdivision the obligation to pay for beneficial services received. Those statutorily-imposed obligations are now made dependent for their efficacy on this court’s willingness to support their enforcement by supplying the critical implied-in-law (quasi-eontractual) promise. The legislature will never know — when in the future it creates a statutory obligation— whether the court will enforce it by providing the critical promise.

Even though the court does not view the statute that created the obligation as constitutionally infirm, it nonetheless cavalierly exonerates an entire class of obligors from performance of a legislatively imposed obligation. Today’s pronouncement plainly provides delinquent school districts with a generous escape hatch by destroying all avenues of enforcement available against them. There is no jurisprudential support for today’s ipse dixit that distorts the school district’s statutory obligation. Legislative power to create obligations that fall into the class here in controversy is not subject to quasi-contractual principles.

By sheer judicial fiat the court first transmogrifies a legislatively imposed duty to pay into an implied-in-law obligation and then invalidates it as an unbudgeted “debt”. This distortion is achieved by labeling as a debt the duty of a political subdivision to obey the legislative act that creates an explicit and unequivocal obligation to pay money for services received or to be received. The opinion’s prospective reach (a) casts a heavy constitutional cloud over extant legislation5 that codifies the M«.sfco,gee-prescribed regime and (b) needlessly undermines the force of the post-Muskogee enactment whose validity is facially crippled.

Today’s pronouncement is more concerned with the pretense of protecting taxpayers from additional levies than with stopping games of lawlessness at the courthouse. My *310concerns, on the other hand, focus (1) on fidelity to valid legislative enactments; (2) on lawful interaction of revenue recipients within the courthouse; and (3) on enforcing against all these recipients, fairly and evenhandedly, the duties imposed by the legislature rather than on making some of these obligors virtually untouchable by present enforcement remedies. Were I writing for the court, I would put a stop to the courthouse games by making them far too expensive to play for the individual school district-obligors and for the responsible officials involved. Offending school district officials must be held accountable for their failure to obey the statute’s mandate. They should not be, as they are today, judicially licensed to ignore their duty with absolute impunity.

II

THE ANATOMY OF LITIGATION

The Tulsa County Assessor [Assessor] sought mandamus to compel Tulsa County Independent School Districts Nos. 1, 5 and 11 and their respective boards [Districts] to pay their proportionate share of the Assessor’s 1992-93 visual inspection budget for the ad valorem property tax revaluation program in compliance with the terms of 68 O.S.1991 § 2823.6 The Districts objected to the payment because they neither (a) had received notice that the visual inspection budget had been increased by approximately $525,000 nor (b) had they been afforded an opportunity to protest the increase before the Tulsa County Excise Board [Board] as required by 68 O.S.Supp.1992 § 2822.7 At the March 30, 1993 hearing the district judge stated that (a) because the Districts had not received the statutorily mandated notice of the county’s amended budget, he would hold the mandamus action in abeyance until the Districts had an opportunity to appear before the Board and (b) he would then entertain any “administrative appeal” that might be brought from the Board’s decision as ancillary to the main (mandamus) action before him. The Districts then filed a protest with the Board. After a two-day hearing, the Board denied, on April 23, 1993, the Districts’ challenge and upheld the amended visual inspection budget.

On April 27, 1993 the Assessor filed in the mandamus proceeding a “renewed motion” to compel payment of the Districts’ 1992-1993 share of the revaluation budget. In their June 1, 1993 trial brief the Districts pressed for reversal of the Board’s decision. The trial court (a) affirmed the Board’s ruling and (b) granted mandamus commanding the Districts to pay their share of the visual inspection budget. The Districts brought an appeal from that decision.

In a nisi prius post-mandamus proceeding the Districts moved to settle the journal entry of judgment, urging the trial court to include a statement that their adjudicated obligation may be satisfied by resort to the sinking funds.8 The district court refused to set out the permissible enforcement procedure, stating that its earlier writ of mandamus “resolves all issues in the case.” The Districts then amended their petition in error, pressing for review of the post-mandamus order as well.

The Court of Appeals affirmed, holding that while (1) the statutory scheme for mandatory ad valorem tax revaluation is constitutional, (2) the mandamus order does not constitute a money judgment that may be satisfied from the sinking funds.

Ill

THE STATUTORY AD VALOREM TAX VISUAL INSPECTION/REVALUATION PROGRAM

The statutory ad valorem tax visual inspection/revaluation program is a comprehensive statewide regime for affecting all taxable property within each county of the State.9 *311The process of revaluation must be carried out on a continuous basis and occur at least every four years.10 Each county assessor must make adequate provision for the project and submit to the county excise board— for review and approval — a special budget to be treated as separate from that which is regularly prepared.11 The excise board then apportions the cost among the recipient entities of the affected ad valorem tax revenue.12 The recipients are entitled to receive a copy of the visual inspection budget and may appear before the county excise board to make comment concerning the costs to be taxed.13 It is by this regime that a statutory duty is imposed on each recipient entity to pay its share of the visual inspection program.14 Because schools are recipients of ad valorem tax revenue, the school districts stand subject to this explicitly imposed statutory duty.

IV

EXTANT JURISPRUDENCE PROVIDES A FIRM FOUNDATION FOR TREATING A MANDAMUS-BASED DUTY TO PAY AS A SINKING FUND OBLIGATION

Board of County Commissioners of Muskogee County v. City of Muskogee15 — whose parameters are needlessly narrowed by today’s opinion — teaches that a mandamus *312writ16 commanding the performance of a statutory duty to pay is the functional equivalent and the legal analogue of a money judgment. Extant jurisprudence undergirds this principle and in no way limits its application solely to budgeted expenses.17 Money judgments against school districts may be satisfied in only one fashion — by resort to the constitutional18 and statute-mandated19 sinking fund. It hence follows that when the legislature has cast upon the Districts a duty to pay their proportionate share of revaluation costs, the order that commands them to make such payment represents a sinking fund obligation ex lege.20

Because I would neither erase the settled law’s memory nor ignore binding precedent, I would hold today that a writ of mandamus to pay revaluation costs calls for the perfor-*313manee of a statute-imposed duty and hence represents a sinking fund obligation as a matter of law. This solution would avoid coming to grips with the constitutional infirmity addressed by the court’s opinion.

[[Image here]]

Judicial Scrapping of the Muskogee Sinking-Fund Remedy

The court holds that mandamus can never be used to create a sinking fund obligation without an appropriated annual expense. None of the cases the court cites for this spurious doctrine stands for the invoked proposition21 Today’s pronouncement allows mandamus as a remedy only if (1) funds have been appropriated, (2) the Assessor had included the revaluation costs in her annual budget, (3) unspent budgeted funds of the obligor were available to pay the Districts’ share, (4) the mandamus claim is pressed in the fiscal year for which revaluation costs are sought to be recouped and (5) fiscal confusion (i.e., a year-end payment order) will not result.

The court’s ill-crafted substitution for settled law ignores the offending officials’ (recalcitrant obligor-agencies’) statutory duty to budget and to pay their share of the revaluation costs. Today’s approach errs by wrongly superimposing upon the statute’s unequivocal command the obligee’s (Assessor’s) extra-statutory burden (a) to monitor the district’s budgets, and (b) to seek and secure mandamus during the fiscal year for the obligation in order to compel an obligor to include, and the Excise Board to approve, an appropriation for the revaluation expense.

g

The Impact of the Muskogee-prescribed Regime is Unnecessarilg Narrowed

Today’s constriction of the Muskogee analysis rests on the view that when an obligor is allowed to resort to sinking funds for satisfaction of an unbudgeted revaluation liability, a penalty is levied on taxpayers, contrary to the constitutional “cash” or “pay-as-you-go plan.”22 The court’s conclusion is unsupported by extant jurisprudence. Graves v. Bd. ofComm’rs. of Cimarron County23 cited in the opinion, is inapposite. That case found constitutionally infirm an obligation rested upon a voluntarily-entered contract, much the same as the court’s teaching in Del City v. FOP Lodge No. 1⅜24 These authorities are plainly both inapplicable to and dissimilar from the case before the court today, which deals with an involuntary duty cast by the law’s command rather than with a voluntary contractual obligation. Law-imposed obligations are free from the budgeting strictures of Art. 10, § 26, Okl. Const.,25 whose provisions prohibit public funds from being encumbered beyond a single fiscal year. An uninterrupted line of authority unequivocally supports this long-recognized exception for statute-cast duty.26 Today’s opinion marks the only departure.

Sinking funds are constitutionally mandated.27 Resort to them must be treated as an authorized exception (to the provisions in Art. 10, § 2628) for collection of all law-imposed liabilities that are involuntarily in*314curred.29 There is no authority for the court’s refusal today to honor the settled doctrine.

Y

WITHOUT ANY TEXTUAL OR JURISPRUDENTIAL WARRANT, TODAY’S PRONOUNCEMENT TRANSMOGRIFIES A LEGISLATIVELY-IMPOSED LIABILITY INTO A QUASI-CONTRACT

The narrow question to be answered here is whether the legislature, having created an explicit duty to pay and a status relationship between the county-obligor and the school district as an obligee, has the power to expect that its statute-commanded obligations will be enforced without judicial interposition of a promise to pay through the fiction of a quasi-contract. The public-law duty to pay revaluation costs is based on an obligor-obli-gee status relationship between two public-law entities. By that legislative status the school district is made the obligor and the county its obligee.

The court’s opinion arbitrarily (and sans legal authority) labels the Districts’ post-fiscal-year statutory revaluation obligation as one in quasi-contract and enforceable in as-sumpsit.30 It reasons that because the remedy for this obligation’s breach is to be treated as one on the contract, it constitutes a “debt” within the meaning of the limit imposed by Art. 10, § 26, Okl. Const.31 The Assessor’s claim to this obligation is erroneously downgraded as subject to the terms of 62 O.S.1991 §§ 361-363, which require (1) an appropriation of funds and (2) an itemization of the contractual indebtedness sought to be reduced to judgment. Today’s unwarranted mischaracterization of the revaluation obligation as quasi-contractual transforms the law’s existing command to pay the revaluation expense into a worthless implied-in-law promise which, when unbudgeted, becomes unenforceable.

There is no extant Oklahoma jurisprudence to support the court’s quasi-contractual analysis. The theory is not only harmful but unnecessary as well. For the enforcement of obligations, pre-1600 English common law was dominated by the concept of duty cast rather than of promise fulfilled,32 *315The duty cast was one that was either voluntarily entered into, in which case it was called vinculum juris (or iuris),33 or one east by law regardless of any act by the obligor. In the latter case it was called vinculum legis. When the law moved from status and duty to promise by developing the principles of modern contract,34 the earlier notion of duty survived to continue in existence parallel with promise-based obligations. Duty-based obligations, long cognizable at common law, continue to stand unabrogated by statute and undiluted by Oklahoma’s extant jurisprudence:35

The early notion of a quasi-contractual recovery manifests itself in the common count for money had and received,36 which is a purely restitutionary claim.37 The Oklahoma, as well as the English, remedy for recovery of money paid under an unenforceable, void, voidable or otherwise frustrated contract is in quasi-contract.38 An implied-in-law promise will be supplied from one who *316must return that which cannot be kept in good faith.39

Ünlike the examples from restitution, there is no extant authority to support today’s notion that the law must supply a promise from a statutory obligor upon whom a valid enactment has cast, unequivocally and explicitly, the duty to pay.40 This is not an action for restitution. When, as here, the obligor’s liability stands directly and explicitly imposed by law, no promise need be implied. Simply put, the statute creates a duty that is enforceable without a promise (real or fictional). This is so because the statutory liability in contest here is duty-, not promise-based.41 That is enough. The quasi-contract’s implied-in-law promise may be needed only where there is neither a promise nor legal duty to pay.42

I would hence hold that the solemn statutory obligation of a school district, sought to be enforced here, may not be downgraded to a quasi-contractual rubric.

*317VI

UNWARRANTED JUDICIAL EXONERATION OF DERELICT SCHOOL DISTRICT OFFICIALS — WHO VIOLATE THEIR SOLEMN DUTY TO INCLUDE THE REVALUATION OBLIGATION IN THE ANNUAL BUDGET — FROM AMENABILITY TO CIVIL LIABILITY

A.

Civil Liability Provisions of The Ad Valorem Tax Code

By stripping the county government of all civil remedies (for recovering unbudgeted revaluation costs) against recalcitrant school district officials, the court’s analysis leaves the state and counties with no legal choice but that which was doubtless intended by the legislature to be the very last resort — the draconian43 penalty provisions of the Ad Va-lorem Tax Code (68 O.S.1991 § 2943).44

The Assessor’s mandamus petition initially pressed for imposition of the § 2943 penalty provision. She appears to have abandoned that quest when she was later met with the school district officials’ challenge to the statute as applicable only to county and state officers.

B.

All Ad Valorem Tax Recipients Are Impliedly Included Within The § 2943 Penalty Provisions

Because, when the revaluation obligation is unbudgeted, the court leaves the county without any effective remedy at the post-fiscal-year stage, I desire to provide the assessors today with that analysis and guidance which will assist them in enforcing the penalties against recalcitrant school district officials.

Initially, the § 2943 penalty provisions may have targeted only county officials.45 When the statutory scheme was later expanded by imposition of a duty on ad valo-rem tax recipients other than the county offices to reimburse the county for their share of the revaluation cost, noncounty officials automatically came under the aegis of the statute. Insofar as these local officials (other than those of the county) are called upon to discharge duties connected with the revaluation regime, their noneompliance with pertinent statutory commands clearly falls under the purview of § 2943 penalty provisions.

Inasmuch as I would include the school district officials within the ambit of § 2943 and apply the Muskogee analysis to solving the instant controversy, I would not permit the statute’s penalty provisions to be invoked *318except only after a judicial finding that the official dereliction (or nonfeasance) was inexcusable.

C.

Regardless of Whether the § 2943 Penalty Provisions or the Common Law Applies to the School District Officials’ liability For Failure to Include Revaluation Costs In their Budgets, Today’s Opinion Leaves School District Wrongdoers Absolved of Any Civil Liability

By her abandonment of the issue the assessor seemingly concedes the § 2943 penalty provisions are not applicable to the school districts. Whether these provisions or the common law46 should govern, the school district officials’ liability for their dereliction of duty stands eliminated as an issue by the court’s unwarranted cavalier exoneration of all school districts of any responsibility for failing timely to submit the revaluation obligation for inclusion in the annual budget. Today’s opinion clearly sets a course that will enable offending school district officials to violate their statute-imposed duty with utter impunity.

YII

THE PROSPECTIVE REACH OF TODAY’S PRONOUNCEMENT CASTS AN UNWARRANTED CONSTITUTIONAL CLOUD ON RECENT POST-MUSKOGEE AMENDMENTS IN UTTER DISREGARD OF THE PRUDENTIAL RULE OF STRICT NECESSITY

The legislature carried into statutory form the Muskogee-prescribed enforcement regime shortly after the case was handed down by this court.47 Under the statutory scheme now in force, when there is an absence of appropriated funds, sinking funds are to be impressed with a charge for payment of an adjudicated revaluation obligation. The pertinent terms of 68 O.S.Supp.1994 § 2823(C) provide:

a * * * ^ ⅛@ case 0f a giniáng ⅛ 0f a recipient, if, after approving its budget, the governing body of a recipient notifies the board in writing that there are no funds appropriated to pay the amount of the billing statement for such sinking fund, such notice shall constitute conclusive evidence of a financial obligation of the recipient as it relates to such sinking fund. The board may seek a judgment for the amount of such obligation....” (Emphasis added.)

The court’s opinion would trump the cited legislation by an out-of-hand ukase48 of invalidity passed in advance of a lively and justiciable controversy over the amended act’s conformity to our fundamental law. Today’s pronouncement clearly violates the prudential bar of restraint49 by casting a serious and unwarranted doubt on the constitutional validity of post-Muskogee legislation. Constitutional clouds must not be injected in advance of strict necessity. When, as here, the legal relief sought may be afforded upon alternate grounds, the consideration of fundamental-law challenges is inappropriate under the judiciary’s self-erected and time-honored “prudential bar” of restraint.

*319VIII

SUMMARY

The revaluation obligation is not a debt. It is an explicit law-imposed command that creates a duty to pay. Its terms are enforceable sans implied-in-law promise. There is no statutory or jurisprudential warrant for transforming the statutory mandate into an implied-in-law promise that is made subject to the axe of Art. 10, § 26, Okl. Const. Today’s abandonment of the Muskogee collection method in favor of a quasi-contractual solution impermissibly exonerates school districts as well as their offending officials of any duty to tender the revaluation obligation for inclusion in the district’s annual budget and of any responsibility for their non-, mis- or malperformanee for which they should be made civilly accountable.

There is no need for the opinion’s prospective reach. All that is required today is to decide the school districts’ liability in this case. The prudential bar of restraint militates against gratuitously casting a constitutional cloud on the post-Muskogee legislative enactments which contemplate payment of delinquent unbudgeted revaluation costs from sinking funds.

I would reaffirm all of Muskogee’s school-district liability teachings and make offending school district officials hable for failure timely to tender the revaluation obligation for inclusion in the annual budget. For their dereliction of that duty I would impose the very same penalty as that which applies to county officials under the provisions of § 2943.

. Okl., 820 P.2d 797, 810 (1991).

. 62 O.S.1991 §§ 431, 435, infra note 19; Board of Educ., infra note 20, 43 P.2d at 140; Goerke, infra note 20, 126 P.2d at 1006.

. “Purely prospective” means that the opinion has no effect upon the obligation in controversy. See Harry R. Carlile Trust v. Cotton Petroleum, Okl., 732 P.2d 438, 447-448 nn. 46, 49 (1987), which gives purely prospective sweep to a new constitutional rule declared in a collateral attack upon a Corporation Commission spacing order.

. See the terms of 68 O.S.1991 § 2943, infra note 44.

. See Part VII infra for the text of 68 O.S.Supp. 1994 § 2823(C).

. For the pertinent provisions of 68 O.S.1991 § 2823(A), see infra note 11.

. For the pertinent terms of 68 O.S.Supp.1992 § 2822(B) and (C), see infra note 13.

. For the terms of Art 10 § 28, Okl. Const., and 62 O.S.1991 § 431 — which require maintenance of sinking funds — see infra notes 18 and 19.

. The terms of 68 O.S.1991 § 2820(A) provide:

*311“Each county assessor shall conduct a comprehensive program for the individual visual inspection of all taxable real property within his respective county. Each assessor shall thereafter maintain an active and systematic program of visual inspection on a continuous basis and shall establish an inspection schedule which will result in the individual visual inspection of all taxable real property within the county at least once each four (4) years."

See also 68 O.S.1991 § 2821, pertaining to physical inspection as part of the visual inspection.

. 68 O.S.1991 § 2820(A), supra note 9.

. The terms of 68 O.S.Supp.1992 § 2822(A) (eff. June 9, 1992) are:

"Each county assessor in budgets submitted to the county excise board or county budget board shall make adequate provision to effect countywide visual inspections of real property during the four-year cycle.” (Emphasis added.)

The 1993 and 1994 amendments to § 2822 have no legal effect on this case.

The terms of 68 O.S.1991 § 2823(A), the version applicable to this case, provided:

“For the fiscal year beginning July 1, 1992, and each year thereafter, the cost of the comprehensive program of visual inspection for real property shall be paid by appropriate warrants from those who receive the revenues of the mill rates levied on the property of the county as prescribed by this section. The county assessor shall prepare a budget for the comprehensive program of visual inspections for real property and file such budget with the county excise board or county budget board.” (Emphasis added.)

The 1992 and 1994 amendments to § 2823 have no legal effect on this case.

. The pertinent terms of 68 O.S.1991 § 2823(B) and (D) are:

“B. The county excise board or county budget board shall apportion such cost among the various recipients of revenues from the mill rates levied, including the county, all cities and towns, all school districts, excluding any sinking funds of such recipients .. ■
******
D. The county assessor shall render a statement to each of the jurisdictions within the county which receive revenue from an ad valo-rem mill rate excluding sinking funds." (Emphasis added.)

The 1992 and 1994 amendments to § 2823 have no legal effect on this case.

. The terms of 68 O.S.Supp.1992 § 2822(B) and (C) provide in pertinent part:

"B. Each jurisdiction within a county which receives revenue from an ad valorem mill rate shall receive a copy of the budget for the countywide visual inspection program for that county. Such jurisdictions shall have the opportunity to appear before the county excise board or the county budget board to provide comments, information and documentation concerning the budgets submitted by the county assessor pursuant to subsection A of this section.
C. The several county excise and budget boards, in passing upon budgets submitted by the several assessors, shall authorize and levy amounts which will suffice to carry out the countywide visual inspection program as approved by the Oklahoma Tax Commission under Section 2820 of this title. Any disputes as to the amount authorized to carry out the countywide visual inspection program shall be resolved by the county excise board." (Emphasis added.)

The 1993 and 1994 amendments to § 2822 have no legal effect on this case.

. 68 O.S.1991 § 2823(A), supra note 11; Muskogee, supra note 1 at 803.

. Muskogee, supra note 1 at 809.

. The terms of 12 O.S.1991 § 1451 are:

“The writ of mandamus may be issued by the Supreme Court or the district court ... to any inferior tribunal, corporation, board or person, to compel the performance of any act which the law specially enjoins as duty resulting from an office, trust or station; but though it may require an inferior tribunal to exercise its judgment or proceed to the discharge of any of its functions, it cannot control judicial discretion." (Emphasis added.)

The terms of 12 O.S.1991 § 1452 are:

"This writ may not be issued in any case where there is a plain and adequate remedy in the ordinary course of the law. It may be issued on the information of the party beneficially interested."

. Braine v. City of Stroud, Okl., 385 P.2d 428, 430 (1963); In re Epley, 10 Okl. 631, 64 P. 18, 19-20 (1901). See also State v. District Court of Mayes County, Okl., 440 P.2d 700, 708 (1968) (overruled in part on other grounds by Palmer v. Belford, Okl., 527 P.2d 589, 592 (1974)); Smiley v. City of Tulsa, 159 Okl. 195, 14 P.2d 942, 943 (1932).

. The pertinent terms of Art. 10, § 28, Okl. Const., are:

“[Sjchool districts ... shall levy sufficient additional revenue to create a sinking fund to be used ... for the payments of such parts of judgments as such [districts] may, by law be required to pay.” (Emphasis added.)

. The terms of 62 O.S.1991 § 431 provide in pertinent part:

"It shall be the duty of the officers of each municipal corporation in the State of Oklahoma by law authorized to levy taxes to make a levy each year for a sinking fund, which shall ... be sufficient to pay ... [a] sum ... equal to one-third (½) of the original amount of all outstanding judgements against the municipality when one-third (⅛) or more of each judgment remains due and unpaid, and in case less than one-third (½) of such judgment remains due then for the entire amount of such judgment yet remaining unpaid ...” (Emphasis added.)

The pertinent terms of 62 O.S.1991 § 435 are:

"... Such sinking funds shall be used ... [f]or the payment of judgments against the municipality ...." (Emphasis added.)

The pertinent terms of 62 O.S.1991 § 365.5 were:

"Money judgments against any county or other municipal subdivisions of the State of Oklahoma shall be paid in the following manner, and may be paid in no other manner .... [The municipal treasurer] shall ... canvass his sinking fund for the purpose of ascertaining if there be in his sinking fund for such municipality an amount of actual cash over and above the amount of cash needed to pay all coupons and bonds matured and maturing therein within the time such sinking fund will be replenished from levies made or to be made for such judgment ... he shall approve such claim in such amount as is neither in excess of such claim nor in excess of the actual cash reserve necessary for coupons and bonds as hereinbe-fore defined and shall transmit it to the clerk of such municipality.” (Emphasis added.)

The 1994 amendment to § 365.5 has no legal effect on this case.

The terms of 62 O.S.1991 § 361 were amended in 1993 to provide:

“The term "judgment” shall be construed to mean the final determination by any court of competent jurisdiction in any action or proceeding to determine the rights of parties.” (Emphasis added.)

Okl.Sess.L.1993, Ch. 318, § 3 (62 O.S.Supp.1993 § 361). A mandamus order determines the rights of parties to an action in which it is sought. See Braine, supra note 17 at 431; Mayes County, supra note 17 at 708. While the 1993 amendment has no legal effect on this litigation, it is entirely consistent with the teachings of Muskogee, supra note 1 at 809-810.

. 62 O.S.1991 §§ 431, 435 supra note 19; Muskogee, supra note 1 at 810; Bd. of Educ. v. Bd. of County Com'rs, 171 Okl. 464, 43 P.2d 139, 140 (1935); State v. Goerke, 191 Okl. 1, 126 P.2d 1005, 1006 (1942). Primary resort must be had to the budgeted funds. Only upon their exhaustion may a mandamus judgment be enforced against other sources. The trial court's refusal — ■ in the post-mandamus proceeding — to settle the journal entry of judgment by detailing the applicable enforcement procedure is not a bar to the invocation of the Muskogee-authorized collection method.

. For this doctrine the court’s opinion erroneously cites Deal v. Excise Bd. of Pontotoc County, 179 Okl. 73, 64 P.2d 859, 860 (1937); Chaffin v. Excise Bd. of Okmulgee County, 172 Okl. 425, 45 P.2d 480, 482 (1935); Shannon v. Davidson, 33 Okl. 293, 125 P. 1106, 1107 (1912).

. Del City v. FOP Lodge No. 114, Okl., 869 P.2d 309, 311 (1994).

. 170 Okl. 282, 39 P.2d 532, 533 (1934).

. Okl., 869 P.2d 309, 311 (1994).

. For the pertinent terms of Art. 10, § 26, Okl. Const., see infra note 31.

. Board of County Com'rs v. Mullins, 202 Okl. 628, 217 P.2d 835, 842 (1950); City of Claremore v. Oklahoma Tax Commission, 197 Okl. 223, 169 P.2d 299, 303 (1946); Liberty Nat. Bank v. County Excise Board, 175 Okl. 245, 52 P.2d 51, 53 (1935), cf. Del City v. FOP Lodge No. 114, supra note 22.

. For the pertinent terms of Art. 10, § 28, Okl. Const., see supra note 18.

. For the pertinent terms of Art. 10, § 26, Okl. Const., see infra note 31.

. Mullins, supra note 26 at 842; City of Claremore, supra note 26 at 303; Liberty Nat. Bank, supra note 26 at 53.

. Bullard v. Bell, 4 Fed.Cas. 624, 640 (1817).

. The pertinent terms of Art 10, § 26, Okl. Const., are:

"[N]o ... school district ... shall be allowed to become indebted, in any manner, or for any purpose, to an amount exceeding, in any year, the income and revenue provided for such year without the assent of three-fifths of the voters thereof...." (Emphasis added.)

. In the fourteenth century — before the development of assumpsit' — the forms of action used in contractual matters were debt, detinue, account and covenant. James B. Ames, Lectures On Legal History 156, 122 (1913). The oldest contractual action in the fourteenth century was the writ of debt. " * * * [T]he early real contract or simple debt was founded directly on legal duty and did not derive its obligatory force from any word or promise of either party." (Emphasis added.) Thomas Street, The Foundations of Legal Liability, vol. 1, p. 2 (1906). Debt did not imply a promise to pay the creditor; it dealt with a relationship (status) between parties which created a duty. Theodore F.T. Plucknett, A Concise History of the Common Law 633 (5th ed. 1956). In short, the status — not a promise to pay — created the debt. Plucknett at 363. With the debt there was no question of an undertaking. The relationship sprung from the exchange of "grants,” not promises. The grant that the debtor gave to the creditor was the debt itself. A.W.B. Simpson, A History of the Common Law of Contract 80 (1975); Ames, supra at 89. "... [MJedieval lawyers saw a debt as more like property than breach of promise." (Emphasis added.) J.H. Baker, An Introduction to English Legal History 365 (3d ed. 1990). There was also a difference between detinue and debt. Detinue dealt with specific chattels, which were owned; debt dealt with money or fungibles, which were owed (and hence under duty to return or repay). Id. at 365. An action on account generally was applicable to only a few types of relationships, such as partners. Plucknett, supra at 635. The idea of the exchange of mutual promises, coupled with the notion of consideration, did not gain acceptance until after the development and modification of assumpsit itself. Ames, supra at 122. “Prior to ... [1600] the term ‘contract’ meant no more and no less than an obligation actionable in debt.” Street, supra, vol. 2, 59-60. See also R.H. Graveson, Status In The Common Law at 33 (The Movement From Status to Contract) (University of London Athlone Press 1953); Patrick Selim Atiyah, The Rise and Fall of Freedom of Contract, 36-37, 40-143. 163, 416-417 (Oxford University Press 1979); 1 Williston, A Treatise on the Law of *315Contracts, § 32A (Duties Imposed by Law Without Assent Distinguished) at 88-92 (3d ed. 1957); Corbin, Quasi-Contractual Obligations, 21 Yale L.J. 533-537 n. 17 (1912).

. "In the Roman law, an obligation is defined as a vinculum juris, i.e., 'a bond of law,' whereby one party becomes or is bound to another to do something according to law." Black’s Law Dictionary, 1407 (5th Ed.1979). See also Henry Sumner Maine, Ancient Law 314-315 (1883). It is the bond (rather than a promise) that creates a legally enforceable duty. "An obligation is a legal bond, with which we are bound by a necessity of performing some act according to the laws of our State." Inst, of Just., 3, 13 (quoted in Arthur L. Corbin, Quasi-Contractual Obligations, 21 Yale LJ. 532, 552 n. 80 (1912)). As Thomas Street notes (supra note 32, vol. 3, pgs. 7-8):

It is to be observed that the terms 'right' and 'duty' are substantial correlatives. They are, in fact, only different names for different aspects of that legal obligation (vinculum juris), by which men are held in jural relations. The term 'duly' is the name applied to the legal tie when it is viewed from the standpoint of the person who is bound to do; while the term 'right' is used when the same tie is viewed from the standpoint of the person entitled to performance.

. Assumpsit evolved from trespass actions. Baker, supra note 32 at 374 — 375. See Street, supra note 32, vol. 3 at 172-173 (assumpsit is an action on the case in the nature of deceit). At first, a duty was based upon either law and custom or a previous transaction between the parties. Simpson, supra note 32 at 205-207. Eventually the source of the duty evolved into "assumpsit,” which meant that the defendant undertook "to do something, and then did it badly to the damage of the plaintiff.” Baker, supra note 32 at 375. Simple assumpsit became an action for the nonperformance of a parol or simple contract. Restatement of Restitution, pt. I, introductory note, at 15 (1937). Assumpsit was initially available only for the nonperformance on a simple contract. 1 George Palmer, The Law of Restitution 6 (1978). The courts then began to recognize that assumpsit could be used to enforce a debt if the defendant had made a promise to pay it at the same time or after the debt was created. Baker, supra note 32 at 389-392. The latter action, known as indebitatus assumpsit, originated early in the sixteenth century. Slade's Case, 76 Eng.Rep. 1072 (K.B.1602), allowed in-debitatus assumpsit to enforce a debt without proof of a subsequent promise to pay. The “as-sumpsit" itself was presumed.

. Street, supra note 32 at 65 (vol. 2), observes that:

“Our law of contract is unshakably planted upon two conceptions instead of one. The idea of contractual duty imposed by law, which was the first conception of contract revealed in the common law, eternally abides. It has not been supplanted; it has only been in a measure obscured by the modem conception of the obligation of promise .... [T]he sole clue to a proper understanding of quasi-contracts is found in the ancient and indestructible conception of contractual duty imposed by law. A thing to be constantly borne in mind by the student of modern contract law is that in dealing with the mysterious implied promise, he is really in contact with the simple debt in disguise. The implied promise is purely a remedial fiction. Slade’s Case ... sheds a false light on the subsequent history of contract, because it so easily gives rise to the misleading inference that the conception of the debt has been superseded and extinguished by the notion of the obligation of promise.” (Emphasis added.)

. Baker, supra note 32 at 410.

. Arthur Rosett, Contract Law And Its Application 341 (4th ed. 1988).

. The quasi-contractual obligation arises "without reference to the assent of the obligor, from the receipt of a benefit the retention of which is unjust, and requiring the obligor to make restitution.” Frederic C. Woodward, The Law of Quasi Contracts 4 (1913). For a general discussion of implied-in-law contracts, see Shebester v. Triple Crown Insurers, Okl., 826 P.2d 603, 610 (1992); see also Hughes v. Reed, 46 F.2d 435, 440 (10th Cir.1931). A quasi-contractual obligation is one *316imposed by the legal fiction of a promise implied inlaw. Shebester, supra at 610 n. 30.

. See this court’s holding in Burford v. Bridwell, 199 Okl. 245, 185 P.2d 216, 218-219 (1947), where the applicable rule is said to be that a purchaser of realty cannot recover money paid on the purchase price under an unenforceable contract, which the seller has not repudiated, but is ready, willing, and able to perform. Roussel v. Russell, Okl., 339 P.2d 522, 527-528 (1959) and Hawkins v. Wright, 204 Okl. 55, 226 P.2d 957, 962-963 (1951), declare a similar application of quasi-contractual principles.

. The federal and state cases cited in support of the court’s quasi-contractual analysis are inappo-site to this case. The court relies on U.S. v. P/B STCO, 756 F.2d 364 (5th Cir.1985), Metropolitan Railroad Co. v. Dist. of Columbia, 132 U.S. 1, 10 S.Ct. 19, 33 L.Ed. 231 (1889); Wyandotte Co. v. United States, 389 U.S. 191, 88 S.Ct. 379, 19 L.Ed.2d 407 (1967); Inhabitants of Milford v. Commonwealth, 144 Mass. 64, 10 N.E. 516 (1887). These cases deal with the performance by a third party of another’s statutory obligation, rather than by the legal obligor from whom performance was due. They illustrate that the performance of another's statutory duly can give rise to a claim for unjust enrichment. The issue pressed is whether the third party could recover from the legal obligor and, if so, would the law supply the requisite promise. (1) In P/B STCO, the federal government sought the recovery of the costs of cleaning up oil discharged from barges into navigable waters under the Federal Water Pollution Control Act, 33 U.S.C. § 1321. The act imposes a primary duly on the polluter to clean up and, upon its nonperformance, authorizes the federal government to clean up and recover its costs. (2) Similarly, in Wyandotte, the federal government pressed for recovery of its removal costs under the Rivers and Harbors Act, 33 U.S.C. § 409, which imposes a duty on the owner of a negligently sunk vessel to remove it from navigable waters. (3) In Metropolitan, the District of Columbia sought recovery of costs incurred in paying a third party to do paving work that the obligor was required to do under the District’s charter. (4) In Milford, the town sought recovery (from the State) of expenses incurred in the support of a state pauper. Other cases relied upon deal with (a) private litigation for the recovery of statutorily authorized fees (Harris v. Christian, 10 Pa. 233 (1849) (an alderman’s estate pressed for statutorily authorized fees for services rendered by the decedent); (b) Steamship Co. v. Joliffe, 69 U.S. (2 Wall.) 450, 457, 17 L.Ed. 805 (1864) (a pilot, whose services were declined by a shipowner, made a claim prescribed by statute for one-half of the pilotage fees; the transaction between the pilot and the shipowner gave rise to a quasi contract) and (c) a refund of a license fee (Augner v. Mayor of the City of New York, 14 App.Div. 461, 26 N.Y.Civ.Pro.Rep. 165, 43 N.Y.S. 803 (1897) (a promise was implied to refund a pro rata share of the license fee paid by the plaintiff covering the period during which the government had abrogated his license)).

Here, the duty is sought to be enforced by the statutory obligee against the statutory obligor, not by a third-party performing the defendant's duty. Today's reliance on federal and state jurisprudence for imposing quasi-contractual dimensions upon explicit, direct and unequivocal revaluation liability is without any legal warrant or precedent. Moreover, federal courts have no role in shaping the general body of the common law. Erie v. Tompkins, 304 U.S. 64, 78, 58 S.Ct. 817, 822, 82 L.Ed. 1188 (1938).

. Mercury Investment Co. v. F.W. Woolworth Co., Okl., 706 P.2d 523, 529-530, n. 14 (1985); Cameron & Henderson v. Franks, 199 Okl. 143, 184 P.2d 965, 972 (1947).

. In Anderson v. Copeland, Okl., 378 P.2d 1006, 1007 (1963), the court, quoting from Piggee v. Mercy Hospital, 199 Okl. 411, 186 P.2d 817, 818 (1947), states: " ‘Contracts implied by law, or more properly quasi or constructive contracts, are a class of obligations which are imposed or created by law without regard to the assent of the parties bound, on the ground that they are *317dictated by reason and justice, and may be enforced by an action ex contractu.' "

. The term “draconian” owes its origin to Draco, an Athenian lawgiver, who in 621 B.C. would impose decapitation as a fit punishment for stealing cabbage. Burton v. Planning Commission of the Town of Redding, 209 Conn. 609, 553 A.2d 161, 165 (1989).

. The terms of 68 O.S.1991 § 2943 (eff. January 1, 1992) are:

"The provisions of the Ad Valorem Tax Code relating to the duties of various officials, and the time within which such duties shall he performed, are hereby declared to be mandatory; and the failure of any such official, board or commission, to perform the duties prescribed herein, within the time specified, shall subject them to removal from office for neglect of duty; and they shall receive no remuneration, compensation or salary for their services, after the time herein fixed for the performance of such duties and until the same shall have been completed or performed. Each of them shall also be subject to a penalty of Five Dollars ($5.00) per day for each day's delay for such neglect or failure; and it shall be the duty of the district attorney as to county officers, and the Attorney General as to state officers, to institute proper action to collect any such penalty; provided, that the validity of any assessment or levy shall not be affected because of any insufficiency, informality or delay in the performance of any duty imposed upon any official, board or commission." (Emphasis added.)

.The legislature first enacted the penalty provisions in 1933 (now codified in 68 O.S.1991 § 2943, supra note 44) as a part of a comprehensive act relating to the assessment and equalization of property for ad valorem taxation. Okl. Sess.L.1933, Ch. 115, p. 251, § 13. The 1941, 1961, 1965, 1981 and 1988 amendments did not substantially change the 1933 text. The visual inspection regime, which imposes the revaluation obligation on recipients of ad valorem tax *318revenue, came much later to Oklahoma law. See Okl.Sess.L.1967, Ch. 359, § 4.

. See, e.g., Hazlett v. Board of County Commissioners, 168 Okl. 290, 32 P.2d 940 (syl. 4) (1934).

. 68 O.S.Supp.1994 § 2823(C).

. "Ukase" is a "decree or edict, having the force of law, issued by the Russian emperor or government.” The Oxford English Dictionary, vol. 18, p. 811 (2d ed. 1989). See State v. Lynch, Okl., 796 P.2d 1150, 1166 (1990) (Opala, V.C.J., concurring in part and dissenting in part); Tedford v. Divine, Okl., 734 P.2d 283, 285 (1987); American Bank of Commerce v. Chavis, Okl., 651 P.2d 1321, 1324 (1982); Olinghouse v. Olinghouse, Okl., 265 P.2d 711, 715 (1954) (Halley, C.J., dissenting).

.The prudential rule of strict necessity is adhered to today by all state and federal courts. In re Initiative Petition No. 347 State Question No. 639, 813 P.2d 1019, 1037 (1991) (Opala, C.J., concurring); Smith v. Westinghouse Elec. Corp., Okl., 732 P.2d 466, 467 n. 3 (1987); I.N.S. v. Chadha, 462 U.S. 919, 103 S.Ct. 2764, 77 L.Ed.2d 317 (1983); Ashwander v. Tennessee Valley Authority, 297 U.S. 288, 347, 56 S.Ct. 466, 483, 80 L.Ed. 688 (1936) (Brandeis, J., concurring). See also Schwartz v. Diehl, Okl., 568 P.2d 280, 283 (1977); Dablemont v. State Department of Public Safety, Okl., 543 P.2d 563, 564 (1975).