class. The dissent by Justice Russell M. Nigro did not state that he thought that the college should not be tax-exempt, only that the rest of the court had "so broadly construed its requirements that any private college or university can satisfy the test and obtain tax-exempt status." Legislative response In response to these legal challenges over Washington & Jefferson College's tax-exempt status, the Pennsylvania General Assembly unanimously passed House Bill 55 of 1997, the Institutions of Purely Public Charity Act. The legislation was passed days before the court's decision, when it was yet unclear how the court would rule in that case. Both the court decision and the legislation preserved the tax-exemption for colleges, maintaining the status quo. The bill provided uniform standards for determining the tax-exempt eligibility for all nonprofits, especially private colleges. The bill clarified the law and has had a long-term impact on other nonprofits besides private colleges, including hospitals, nursing homes, and public universities. Brian C. Mitchell, President of the Council of Independent Colleges and Universities of Pennsylvania (CICU), was instrumental in getting the bill enacted. In 1998, he was named President of Washington & Jefferson College. His experiences at president of the CICU were cited in his election announcement. In 2009, when Pittsburgh Mayor Luke Ravenstahl proposed a 1% tax on college tuition for students at Pittsburgh colleges, this case was used to argue against the constitutionality of that proposal. Attempts to levy a "service fee" on college students In 1995, the City of Washington passed Ordinance 1460, which established a "service fee" for municipal services that was targeted at Washington & Jefferson College students. The college appealed this ordinance to the Courts of Common Pleas of Washington County, arguing that "the ordinance is an illegal tax ordinance, not authorized by statute." In an opinion written by Judge David L. Gilmore, the court ruled that the "service fee" was actually a "tax masquerading as a fee" and that the label was "given to it merely to avoid the problem presented by enacting such a tax." The court noted that there was no legal basis for calling this ordinance a tax rather than a service fee, since the city admitted that it was facing budgetary shortfalls and had passed the ordinance in search of new revenue. According to the judge, the "ordinance attempts to raise additional revenue thereby creating a tax," which was not authorized