Maple Run at Austin Mun. Util. Dist. v. Monaghan - 931 S.W.2d 941 (Tex. 1996)

Rule:

A law is not a prohibited local law merely because it applies only in a limited geographical area. The legislature has broad authority to make classifications for legislative purposes. However, where a law is limited to a particular class or affects only the inhabitants of a particular locality, the classification must be broad enough to include a substantial class and must be based on characteristics legitimately distinguishing such class from others with respect to the public purpose sought to be accomplished by the proposed legislation. The primary and ultimate test of whether a law is general or special is whether there is a reasonable basis for the classification made by the law, and whether the law operates equally on all within the class.

Facts:

The lower court agreed with appellees landowners and city and entered judgment that Tex. Loc. Gov't. Code Ann. § 43.082, which permitted dissolution of the utility district, annexation of it without notice and hearing procedures, and required the city to take ownership of the district's assets and assume its debts, unconstitutional and permanently enjoined its operation. Appellant utility district sought review of the judgment.

Issue:

Did the subject law violate the Texas Constitution?

Answer:

Yes.

Conclusion:

The subject law was not authorized under Tex. Const. art XVI, § 59, and therefore was a prohibited local law. A statute that singled out a specific utility district for special treatment, requiring annexation and assumption of its indebtedness by the city without their consent, and without any reasonable basis, was a local law and unconstitutional.