Wash. Supreme Court published opinion — 897239.pdf

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

Related Parts of This Source

Full Text

1,754 chars

description of the measure, and the question of whether or not the measure should be

enacted into law." Wash. Ass 'nfor Substance Abuse & Violence Prevention v. State,

174 Wn.2d 642, 655, 278 P.3d 632 (2012). 4

A ballot title may be general or restrictive. When a ballot title "suggests a

general, overarching subject matter for the initiative," Wash. Ass 'n of Neigh. Stores v.

State, 149 Wn.2d 359, 369, 70 P.3d 920 (2003), it is considered to be general and

"'great liberality will be indulged to hold that any subject reasonably germane to such

4
To the extent our analysis in Washington Ass 'n ofNeighborhood Stores v. State, 149
Wn.2d 359, 368-69, 70 P.3d 920 (2003), suggested the operative title is limited to the
first sentence of a ballot measure, this suggestion has since been foreclosed. See Wash.
Ass 'nfor Substance Abuse & Violence Prevention, 174 Wn.2d at 655.

6
             
Filo Foods, LLC v. City of SeaTac
89723-9

title may be embraced,"' Amalgamated Transit Union Local 587 v. State, 142 Wn.2d

183,207, 11 P.3d 762 (2000) (quoting DeCano v. State, 7 Wn.2d 613,627, 110 P.2d

627 (1941)). Only rational unity among the matters need exist. City ofBurien v.

Kiga, 144 Wn.2d 819, 825-26,31 P.3d 659 (2001). Rational unity exists when the

matters within the body of the initiative are germane to the general title and to one

another. Id. at 826. In contrast, a title is considered restrictive '"where a particular

part or branch of a subject is carved out and selected as the subject of the legislation."'

State v. Broadaway, 133 Wn.2d 118, 127, 942 P.2d 363 (1997) (quoting Gruen v.

State Tax Comm 'n, 35 Wn.2d 1, 23, 211 P.2d 651 (1949)). In other words, a