In Rodriguez v. Gonzales, 148 Tex. 537, 227 S.W.2d 791, 793 (Tex. 1950), the Court struck down an act that set out special procedures for collecting delinquent taxes. See Rodriguez, 227 S.W.2d at 794. The act only applied to parcels of land greater than 1,000 acres that were situated in counties bordering Mexico and whose title emanated from the King of Spain. See Rodriguez, 227 S.W.2d at 794. The Court held that there was nothing special about these estates that warranted different treatment for tax collection purposes. See Rodriguez, 227 S.W.2d at 794 ("There is no substantial difference in the situation or circumstance of border counties relating to suits for delinquent taxes upon which to base the classification."). The Court stated: "The primary and ultimate test of whether a law is general or special is (1) whether there is a reasonable basis for the classification made by the law, and (2) whether the law operates equally on all within the class."