In Harrisburg School District v. Hickok, 563 Pa. 391, 761 A.2d 1132 (Pa. 2000), the Supreme Court of Pennsylvania considered whether a provision of a state law, the Education Empowerment Act of 2000, was a special law under that state's analogue to Article III, § 33.
In general, the Education Empowerment Act provided for state control over school districts having a history of low test scores.
The challenged provision established an exception to this general scheme: "If a school district is 'a school district of the second class with a history of low test performance which is coterminous with the city of the third class which contains the permanent seat of government,' i.e., if the school district is located in Harrisburg, the secretary is directed not to include the district on the list of schools with low performance, but to immediately certify the district as an 'education empowerment district,'" which would remain under local, rather than state, control. Id. at 1135.
The Court held that the provision was a special law.
As the Supreme Court of Pennsylvania explained, the class created by the Education Empowerment Act of 2000, although defined obtusely through a maze of jargon, was actually a closed class of one consisting of the state capital, Harrisburg. Id.