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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of an initiative we recently upheld in Washington Ass 'nfor Substance Abuse &

Violence Prevention. 174 Wn.2d at 665. The ballot title in that case indicated:

"Initiative Measure No. 1183 concerns liquor: beer, wine, and spirits
(hard liquor).

"This measure would close state liquor stores and sell their assets;
license private parties to sell and distribute spirits; set license fees based
on sales; regulate licensees; and change regulation of wine distribution.

"Should this measure be enacted into law?"

Id. at 647 (quoting State ofWashington Voters' Pamphlet, General Election 19 (Nov.

8, 2011)). In addition to these specific provisions, the measure earmarked a portion of

revenue raised from liquor license fees for the funding of public safety programs,

including police, fire, and emergency services. !d. at 650. Like the structure of

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

Proposition 1, Initiative Measure No. 1183 indicated a general topic and then listed

some but not all of its substantive measures. Despite these more specific details, we

found the title was general, pertaining "to the broad subject of liquor." !d. at 655.

And, although the public safety earmark's connection with the measure's liquor

privatization provisions was arguably tenuous, we found the earmark to be germane to

liquor privatization given the enforcement burdens the measure places on local

governments, and given the legislature's past recognition of the relationship between

liquor regulation and public welfare. !d. at 657-58.

We similarly find that Proposition 1 satisfies the single-subject rule. Although

the title lists various provisions, it also states that Proposition 1 generally "concerns