Wash. Supreme Court published opinion — 897239.pdf

Citation: Wash. Supreme Court published opinion — 897239.pdf
Jurisdiction: Washington (state)
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Original Source: https://www.courts.wa.gov/opinions/pdf/897239.pdf ↗

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I. Single-Subject Challenge

RCW 35A.12.130 provides in relevant part that "[n]o ordinance shall contain

more than one subject and that must be clearly expressed in its title." While no

judicial opinion has interpreted this statutory language, the parties agree that it

3 The parties dispute whether the proceeding before the superior court was a summary

judgment disposition or a bench trial that ended in a declaratory judgment. We conclude
that it was a summary judgment disposition. At the hearing, the trial court made clear it
was relying on the declarations submitted by various parties but not resolving factual
disputes as to the consequences of Proposition 1 on airport operations.

Fila Foods, LLC v. City of SeaTac
89723-9

appears to be an extension of article II, section 19 of our state constitution. We

therefore consider our cases interpreting that constitutional provision.

In determining whether a bill, ordinance, or initiative relates to one general

subject or multiple specific subjects, Washington courts look to the provision's title

for guidance. When classifying an initiative to the people (as opposed to an initiative

to the legislative body), the operative title is the ballot title because "'it is the ballot

title with which voters are faced in the voting booth."' Wash. Citizens Action of

Wash. v. State, 162 Wn.2d 142, 154, 171 P.3d 486 (2007) (quoting Wash. Fed'n of

State Emps. v. State, 127 Wn.2d 544, 555, 901 P.2d 1028 (1995)). Contrary to the

Committee's contention, the ballot title includes more than the first sentence of the

ballot description. It "consists of a statement of the subject of the measure, a concise