## Facts

- A Maryland statute required construction of a public school building in Annapolis as part of the state public school system.
- The statute authorized county school officials to finance the project and directed the City of Annapolis to issue up to $10,000 in municipal bonds, payable in ten years, with interest up to 5%.
- The statute also required the city to levy an annual special tax sufficient to pay the bonds’ interest and principal, with proceeds used for the school building.
- Members of a school board building committee sought equitable relief to compel the city and its officials to issue the bonds and implement the tax.
- The city refused, asserting the statute was unconstitutional and exceeded legislative power over municipal indebtedness and taxation.
- A trial court sustained the city’s demurrer and dismissed the bill.
- The plaintiffs appealed to the state’s highest court.

## Issues

1. Whether the Maryland Legislature may constitutionally compel a municipal corporation to issue bonds and levy a special tax to fund a public school building.
2. Whether financing a school building in Annapolis is a local matter beyond state legislative control, or a matter of statewide public concern.
3. Whether a statute directed specifically at Annapolis impermissibly imposes an unequal or special burden in violation of constitutional limits.

## Decision

- The appellate court reversed the decree sustaining the demurrer.
- The court held the statute valid and constitutional.
- The court concluded the city was legally obligated to issue the bonds and levy the tax as directed to fund the public school building.

## Legal Principles

- The public school system is a statewide governmental function subject to broad legislative control over organization and funding, absent a constitutional restriction.
- Municipal corporations are political subdivisions and instrumentalities of the state; the Legislature may impose duties on them to carry out public purposes, including education.
- The Legislature may direct a municipal corporation to levy taxes for a public purpose and to incur debt through bond issuance when not prohibited by the constitution.
- A statute may validly apply to a single municipality when addressing public education within the statewide system; geographic specificity alone does not make the law unconstitutional.

## Conclusion

The court upheld legislative authority to require a city to issue municipal bonds and levy taxes to finance a public school building, treating public education as a state function and the municipality as subject to legislative control absent an express constitutional prohibition.


Revell v. Mayor, Counselor & Aldermen of Annapolis, 31 A. 695 (Md. 1895)