In the Illinois court case Wirtz v. Quinn, state tax assessments were successfully challenged as they were part of a Public Act that was in violation of the Illinois State Constitution. The Third District Appellate Court of Illinois has struck down four Public Acts since they were in violation of the Single Subject Clause of the Illinois State Constitution. The Single Subject Clause states that a Public Act can only represent one subject as represented by its title. The taxpayer had challenged Public Acts 96-34, 96-35, 96-37, and 96-38 on grounds of the state constitution. The Court found that Public Act 96-34 violated the Single Subject Clause and was void in its entirety, along with the other three acts as they were contingent on the enactment of Public Act 96-34. The Act, titled “An Act Concerning Revenue” included an amendment to the Use Tax Act and Retailers Occupation Tax Act. Specific provision of the Act that are now unconstitutional include the increase of the sales and use tax rate from 1% to 6.25% on candy, soft drinks and grooming and hygiene products as well as the tax increase on wine, beer and alcohol and spirits. These changes were effective September 1, 2009. Although the bill is unconstitutional, there is a moratorium on a rollback of the tax rates. It is not clear whether refunds will be available. The Single Subject Clause was created to prevent the passage of legislation that wouldn’t gather the necessary votes for enactment if it were a stand-alone piece of legislation. As Public Act 96-34 was in violation, it was struck down with its dependent Public Acts. (Wirtz v. Quinn, Ill: Appellate Court, 1st Dist., 3rd Div. 2011)