In Matter of American Reliance Insurance Co., 251 N.J. Super. 541, 598 A.2d 1219 (App.Div.1991), New Jersey based domiciled property and casualty mutual insurers contended that it would be unfair to require them to pay the Fair Act assessments because they had never written automobile insurance, had never been servicing carriers of the JUA and derived no financial benefit from the JUA. Id. 251 N.J. Super. at 548, 598 A.2d 1219. They argued that, among other things, subjecting them to the assessments constituted an unlawful taking of their property without just compensation. That argument was soundly rejected. Guided by State Farm, supra, the Appellate Division construed the pertinent statutes as evidencing a "legislative recognition of the State's overarching constitutional obligation to assure all insurers a reasonable rate of return." American Reliance, supra, at 556, 598 A.2d 1219. That construction, the Court held, led to the conclusion that the Fair Act does not, on its face, impose a confiscatory taking with respect to property and casualty insurers that sell no automobile insurance. In American Reliance, supra, our Appellate Division addressed due process challenges to the assessments upon all PLIGA members under the Fair Act, including even those property and casualty mutual insurance carriers who were not authorized to write automobile insurance in this State. The court flatly rejected the facial constitutional attack, reasoning that the imposition of assessments on all PLIGA members represented a "reasonable method of achieving an appropriate governmental objective," namely to raise revenue to fund the JUA deficit. 251 N.J. Super. at 553, 598 A.2d 1219.In American Reliance, property and casualty insurers argued that the burdened class was unconstitutionally "overinclusive" because they had never written automobile insurance and had never been servicing carriers of the JUA and therefore should not be responsible for payment of the JUA debt. 251 N.J. Super. at 553, 598 A.2d 1219. The Court found no violation of their right to equal protection in spreading the financial burden to a wider circle of insurers. Id.