Maple Run v. Monaghan

In Maple Run v. Monaghan, 931 S.W.2d 941, 945 (Tex. 1996) the Court recognized "the Legislature's broad authority to make classifications for legislative purposes." To determine whether a law that is limited to a particular class or locality is general or is an unconstitutional local or special law: "The classification . . . must be based on characteristics legitimately distinguishing the 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." Maple Run, 931 S.W.2d at 945. The Court found no legitimate reason why the Legislature chose a classification confining the statute at issue to a single municipal utility district. See Maple Run, 931 S.W.2d at 946-47. The statute thus failed the traditional local and special law test. The statute's defenders argued that the otherwise unconstitutional statute should stand because it affected water conservation, a matter of statewide interest. See Maple Runn, 931 S.W.2d at 947. In Maple Run, the Court quoted the fifty-eight-year-old proposition that "where a law . . . 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.'" Maple Run, 931 S.W.2d at 945.