Since we must strictly construe the term "public purpose" as set forth in the applicable eminent domain statute, we acknowledge the distinction of our construction of that term outside the context of eminent domain and specifically in the context of constitutional provisions restricting the use of public funds to expenditures for public purpose. See State ex rel. Brown v. City of Warr Acres, 1997 OK 117, ¶ 18, 946 P.2d 1140, 1144 (determining the term "public purpose" "should not be construed `in a narrow or restrictive sense.'") (citations omitted). We adhere to the strict construction of eminent domain statutes in keeping with our precedent, mindful of the critical importance of the protection of individual private property rights as recognized by the framers of both the U.S. Constitution and the Oklahoma Constitution.

Matter of the Application of Capitol Improvement Auth., 1998 OK 25, ¶ 24, 958 P.2d 759, cert. denied, 119 S.Ct. 174, 142 L.Ed.2d 142 (1998).State ex rel. Brown v. City of Warr Acres, 1997 OK 117, ¶ 22, 946 P.2d 1140; Del City v. FOP, Lodge No. 114, 1993 OK 169, ¶ 5, 869 P.2d 309. ¶ 20 In Capitol Improvement, we held that highway improvement bonds were not "debts" within the meaning of art. 10, § 25 because future legislatures were not bound to appropriate funds for their retirement.

"An economic development plan, in whatever form it takes, will be upheld so long as it serves a public purpose and otherwise meets constitutional requirements." State ex rel. Brown v. City of Warr Acres, 946 P.2d 1140, 1144-45 (Okla. 1997). For an economic development income tax credit to be constitutional, three elements must be present:

Such public schools promote the general welfare, as well as economic development, economic security and prosperity for a municipality. See, e.g., State ex rel. Brown v. City of Warr Acres, 1997 OK 117, ¶ 20, 946 P.2d 1140, 1145 (wherein we held "public purpose" embodies a proposal that promotes the general welfare, economic security and prosperity of the city and its citizens); Burkhardt v. City of Enid, 1989 OK 45, ¶ 23, 771 P.2d 608, 614 (wherein we held "economic development is a public purpose for which a municipality may expend public funds," and determined an institution of higher education provides a public benefit that fosters economic development in a community.) Therefore, we hold that in pursuit of a lawful public function, the City of Oklahoma City and the City of Lawton enacted the ordinances at issue herein.

A municipal governing body (i.e., town board, city council or city commission as the case may be) as the legislative body of the municipality, is ultimately responsible for the municipality's fiscal policy. State ex rel. Brown v. City of Warr Acres, 946 P.2d 1140, 1144 (Okla. 1997). This does not mean the governing body may ignore the mention of a particular service provider in the ballot proposition, but we believe a municipal governing body must exercise sound discretion in monitoring the performance of the private provider.

As held in Sublett v. City of Tulsa,405 P.2d 185, 197 (Okla. 1965) and State ex rel. Brown v. City of Warr Acres,946 P.2d 1140, 1144 (Okla. 1997), the circumstance that a private company may benefit financially does not mean that a public purpose is not being satisfied. Thus, based on a determination by the county commissioners that a toll bridge would serve a valid public purpose, a private corporation can provide this service by a contract (i.e., a franchise agreement) with adequate consideration.

Lawrence v. Schellstede,348 P.2d 1078, 1082 (Okla. 1960); see also State ex rel. Brown v. City of Warr Acres,946 P.2d 1140, 1144 (Okla. 1997) (quoting Lawrence, at 1082). Expenditures resulting in a public use or purpose are not prohibited by Okla. Const. art. X, § 17. Willow Wind, Inc. v. City of Midwest City,790 P.2d 1067, 1070 (Okla.

1938). Courts give great deference to a legislative body's determination that a particular project serves a public purpose, and will reverse such determination "only upon a clear showing that it was manifestly arbitrary, capricious, or unreasonable." State ex rel. Brown v. City of Warr Acres,946 P.2d 1140, 1144 (Okla. 1997). B. Economic Development is a Legitimate Public Purpose.

The determination of what is, or is not, a valid public purpose for use of public money is a matter for the governing body of the entity spending the money to decide. State ex rel. Brown v. City of Warr Acres,946 P.2d 1140, 1144 (Okla. 1997). Absent a showing of fraud or arbitrariness, a finding by a governing body that a project serves a public purpose will not be disturbed by the courts.

That provision's correlative limitation, section 17, was "adopted for the purpose of preventing the investment of public funds in private enterprises." State ex rel. Brown v. City of Warr Acres, 1997 OK 117, ¶ 11, 946, P.2d 1140, 1143-44 (citing Lawrence v. Schellstede, 1960 OK 10, 348 P.2d 1078). The term "public purpose" in article X, section 14 should not be construed "in a narrow or restrictive sense."