In Pennsylvania Turnpike Commission v. Pennsylvania, 587 Pa. 347, 899 A.2d 1085 (Pa. 2006), the Supreme Court of Pennsylvania addressed whether the First-Level Supervisor Collective Bargaining Act, which mandated that the Pennsylvania Turnpike Commission collectively bargain with its first-level supervisors, was a special law.
"First-level" was statutorily defined as "the lowest level at which an employee functions as a supervisor." 43 Pa. Stat. § 1101.301(19).
After noting that the statute, as originally introduced in the legislature, was intended to apply broadly to public employers, 899 A.2d at 1087, the Court invalidated it because, among other reasons, the statute "created a class with one member and did so in a fashion that makes it impossible for another member to join the class," since it "defined 'public employer' as 'The Pennsylvania Turnpike Commission.'" Id. at 1098.