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 ↗

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restrictive title is narrow as opposed to broad, specific rather than generic. !d.

Restrictive titles are not given the same liberal construction as general titles; laws with

restrictive titles fail if their substantive provisions do not fall "'fairly within'" the

restrictive language. Citizens for Responsible Wildlife Mgmt. v. State, 149 Wn.2d

622, 633, 71 P.3d 644 (2003) (quoting State ex rel. Wash. Toll Bridge Auth. v. Yelle,

32 Wn.2d 13, 26, 200 P.2d 467 (1948)).

Here, the ballot title to Proposition 1 stated:

Proposition No. 1 concerns labor standards for certain employers.

This Ordinance requires certain hospitality and transportation employers
to pay specified employees a $15.00 hourly minimum wage, adjusted
annually for inflation, and pay sick and safe time of 1 hour per 40 hours
worked. Tips shall be retained by workers who performed the services.
Employers must offer additional hours to existing part-time employees
before hiring from the outside. SeaTac must establish auditing

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

procedures to monitor and ensure compliance. Other labor standards are
established.

Should this Ordinance be enacted into law?

King County Official Local Voters' Pamphlet, General and Special Election 94 (Nov.

5, 2013). "Other labor standards" includes a 90-day retention policy on successor

employers after a business acquisition or merger. SEATAC MUNICIPAL CODE

7.45.060. The trial court upheld Proposition 1 against Fila Foods's single-subject

challenge. We affirm in this respect.

We agree with the trial court that the breadth of topics covered by Proposition 1

and the structure of its title are not appreciably different from the scope and structure