Samuel Freeman Miller

“ It is, therefore, a corporate power, and was conferred, if at all, by a special act.
In response to this it is said that a school district is only a quasi corporation, and does not come within the constitutional provision. What is meant by the words 'quasi corporation,' as used in the authorities, is not always very clear. It is a phraso generally applied to a body which exercises certain functions of a corporate character, but which has not been created a corporation by any statute, general or special. ”

“ In fact, the weight of the argument seems to be the other way, for it can very well be seen that the aggregation of individual capital and energy into an associated organization may require different powers for each enterprise so established, while the powers to be exercised by cities, towns, townships, and school districts in the same State may or should be uniform in character all over the State. ”

“ We are asked, however, to affirm the judgment because the bonds may be held valid under the powers conferred on school districts by the general statutes.
We are, however, of a different opinion. The general statute had other conditions for creating a debt than the special act mentioned on the face of these bonds. This statute provided a fund which might of itself be sufficient to pay the debt without resort to taxation. The vote of the electors might not have been obtained under the general statute. ”