Minnesota’s Metropolitan Fiscal Disparities Act (the act) imposed a new municipal-tax structure on commercial and industrial businesses. The act applied to a seven-county area with 250 units of local government, including Minneapolis and St. Paul. Historically, taxes from new commercial-industrial development went directly to the municipality that hosted the development. The act changed this by creating a formula that pooled 40 percent of the increased tax revenue realized from new developments, to be distributed proportionally among the other local governments in the region based on their relative fiscal capacity. The new tax system was meant to avoid competition by local governments for new commercial-industrial developments. The system was also meant to allow local governments to plan the orderly growth of their communities without having to focus on the tax revenue that the growth would provide. The result of this tax-revenue pooling was that in any given year some municipalities would contribute more to the pool than they would receive in the distributions. One village, Burnsville (plaintiff) challenged the constitutionality of the act. The trial court held that the tax scheme violated the provision of the state constitution that required that taxes be “uniform upon the same class of subjects.” Several county auditors and a county financial director (defendants) appealed.