State of Indiana v. John Buncich, in his capacity as Chairman of the Lake County Democratic Central Committee, Christine M. Russell, individually, Randolph Palmateer, individually, 51 N.E.3d 136

In 2014 the Indiana General Assembly enacted Ind. Code § 3-11-1.5-3.4, directing creation of a Lake County Small Precinct Committee to identify precincts with ≤500 active voters for potential consolidation to save election costs; the statute applies only to Lake County.
Lake County had an unusually large number of small precincts in 2014 (130 in March, 174 in July), more than any other county and over 15% of the State’s small precincts.
The Committee (made up of the five-member Lake County Board of Elections and two appointed staff) identified dozens of precincts amenable to consolidation and estimated substantial savings; consolidation could eliminate some precinct committeeperson offices.
The Lake County Democratic Central Committee and five precinct committeepersons (Buncich) sued for declaratory and injunctive relief, arguing the statute is unconstitutional special legislation (Art. 4 § 23) and violates separation of powers (Art. 3 § 1) because committeepersons perform state functions and could lose offices.
The trial court granted relief, holding the law an impermissible special statute and a separation-of-powers violation; the State appealed directly to the Indiana Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 3-11-1.5-3.4 is impermissible special legislation under Art. 4 § 23	Buncich: Nearly all counties have small precincts; legislature cannot single out Lake County absent inherent characteristics common to the defined class	State: Lake County’s sheer number and proportion of small precincts are exceptional; a general law is inapplicable and local legislation is justified	Court: Statute is permissible special legislation — Lake County’s abnormal number of small precincts is a sufficiently distinctive, justifying characteristic; uphold statute
Whether statute violates separation of powers (Art. 3 § 1) by affecting precinct committeepersons who perform state functions	Buncich: Committeepersons fill certain state office vacancies and thus perform state functions; removing them implicates separation of powers	State: Precinct committeepersons are local political party officers (not state officers); filling vacancies is a partisan political privilege, and separation clause applies only to state officers	Court: No violation — committeepersons are local party officers outside the state separation-of-powers provision

Zoeller v. Sweeney, 19 N.E.3d 749 (Ind. 2014) (standard: statutes presumed constitutional; de novo review)
Boehm v. Town of St. John, 675 N.E.2d 318 (Ind. 1996) (presumption of constitutionality and burden on challenger)
Baldwin v. Reagan, 715 N.E.2d 332 (Ind. 1999) (facial challenge burden: no set of circumstances test)
Mun. City of S. Bend v. Kimsey, 781 N.E.2d 683 (Ind. 2003) (special‑law analysis requires inherent characteristics to justify local application)
Ind. Gaming Comm’n v. Moseley, 643 N.E.2d 296 (Ind. 1994) (special legislation permissible where general law inapplicable due to local facts)
Williams v. State, 724 N.E.2d 1070 (Ind. 2000) (upholding special legislative relief where local need supported and statute discretionary)
State ex rel. Atty. Gen. v. Lake Super. Ct., 820 N.E.2d 1240 (Ind. 2005) (local uniqueness may justify special legislation when supported by local facts)
Hoovler v. State, 668 N.E.2d 1229 (Ind. 1996) (permitting classification where justificatory characteristic need not match defining characteristic)
Alpha Psi Chapter of Pi Kappa Phi Fraternity, Inc. v. Auditor of Monroe Cnty., 849 N.E.2d 1131 (Ind. 2006) (striking special legislation when class lacks a distinct, justificatory characteristic)