Clean Water Coalition v. the M Resort, LLC, 255 P.3d 247

CWC was formed by an interlocal agreement among Clark County Water Reclamation District and the cities of Henderson, Las Vegas, and North Las Vegas to fund and operate the SCOP regional wastewater project.
AB 6, 26th Spec. Sess. (Nev. 2010) §18 required the CWC to transfer $62 million in securities and cash to the State General Fund for unrestricted use.
The district court granted summary judgment upholding §18 as constitutional.
The CWC and The M Resort challenged §18 as violating Nevada Constitution Art. 4, §20 (local/special taxes) and Art. 4, §21 (uniform general laws).
The court held that §18 is a local and special tax burdensome to the CWC and could have been addressed with a general law, thus unconstitutional under Art. 4, §§20, 21.
We reverse the district court and hold §18 unconstitutional on both grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether AB 6, §18 violates Art. 4, §20 by imposing a tax.	CWC/The M Resort argue it is a local/special tax on a limited entity.	State contends it is a general budget measure outside Art. 4, §20.	Unconstitutional under Art. 4, §20.
Whether AB 6, §18 violates Art. 4, §21 by addressing a statewide issue with a local law.	§18 burdens a local entity for statewide needs.	Budget crisis permits a special law.	Unconstitutional under Art. 4, §21; a general law could apply.

Conservation Dist. v. Beemer, 56 Nev. 104 (Nev. 1935) (local/special laws analysis; general law could apply)
Evans v. Job, 8 Nev. 322 (Nev. 1873) (general law should apply where subject concerns the entire state)
Galloway v. Truesdell, 83 Nev. 13 (Nev. 1967) (limits on legislative authority; constitution governs)
Hess v. Pegg, 7 Nev. 23 (Nev. 1871) (origins of local/special law prohibitions)
State v. Boyd, 27 Nev. 249 (Nev. 1903) (exactions from one locality for others invalid; state taxation must be uniform)