1969]                   OF THE HOUSE OF DELEGATES                       19

"... the statute does not apply to the entire State; consequently, if
the improvements in Montgomery County that are completed as above
mentioned are taxed for State purposes and similar improvements in
the rest of the State are not, the tax would fail to be uniform and
would discriminate against the property owners in Montgomery
County."

The principle of uniformity stated in the Casey case is germane here
because the exemption from State taxation in House Bill 387 applies only
to Allegany County.

Another constitutional objection to House Bill 387 is that there is no
mention in the title that this bill creates an exemption from all other taxes.
We believe that this omission violates Article III, Section 29, of the Mary-
land Constitution which provides that ".... every law ..... shall be described
in its title." The purpose of Article III, Section 29, is to assist the mem-
bers of the legislature in determining the nature of the bills and also to
inform the citizens of the State generally about the proposed legislation
and give them an opportunity to appear before the legislature. Neuen-
schwander v. Wash. San. Com., 187 Md. 67. We believe that the title of
this bill is constitutionally inadequate because there is no reference to the
exemption from all other taxes. If, as in this instance, there exists an
apparent opportunity for misleading the members of the General Assem-
bly and the public, the Maryland Court of Appeals would not hesitate to
strike down the law. See Bell v. Prince George's County, 195 Md. 21.

In Nutwell v. A. A. Co., 110 Md. 667, the Court of Appeals found
Chapter 672 of the Acts of 1908 invalid because it was in conflict with
Article III, Section 29. The title of the Act of 1908, Chapter 672, stated:
"An Act to add two new sections ... to have a license therefor." The
body of the Act, however, exempted certain vehicles and provided that
the owners of vehicles licensed were to be exempted from all other taxa-
tion. The court held that the title violated Article III, Section 29, stating:

"There is not the faintest suggestion in the title of the Act to lead
anyone to suspect that such exempions were, or might be, introduced
in the law. In these respects the title is not only too narrow, but it is
clearly misleading..."

"The tax exemption feature of this Act is one of its essential parts,
and was no doubt inserted to secure its passage. It is inseparably con-
nected with the whole scheme of the Act. It is so important that it
cannot be presumed that the Act would have passed without it."

In a similar vein we believe that the exemption feature of House Bill
378 is one of its essential parts and should have been referred to in the
bill's title.

Finally, we should point out that the State of Maryland is currently
challenging, in the Maryland Tax Court, the constitutionality of an almost
identical existing Public Local Law of Garrett County on the grounds cited
herein. At issue is the validity of an assessment for the purposes of State
taxation of gas producing property which is exempt from State taxation
under the Public Local Laws of Garrett County. The provision for the
exemption is identical to the provision in House Bill 387. The amount of
the assessment in that case is approximately $................ and, if the State