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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labor standards for certain employers." King County Official Local Voters' Pamphlet,

General and Special Election 94 (Nov. 5, 2013). This language is sufficiently broad

to place voters on notice of its contents, including the 90-day worker-retention policy

imposed on successor employers. The retention policy concerns labor standards and

is reasonably germane to the establishment of minimum employee benefits, including

job security. Proposition 1 survives the single-subject challenge. Moving to the

substance of Proposition 1, we next consider whether it can be validly enforced at the

Seattle-Tacoma International Airport under state law.

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

II. Application at the Seattle-Tacoma International Airport

The trial court ruled that Proposition 1 could not be applied at the Seattle-

Tacoma International Airport because it would conflict with the Port of Seattle's

jurisdiction over the airport under RCW 14.08.330. But we must try to harmonize

municipal ordinances with state law when possible; we will invalidate an ordinance

only if it "'directly and irreconcilably conflicts"' with state law. Heinsma v. City of

Vancouver, 144 Wn.2d 556, 564, 29 P.3d 709 (2001) (quoting Brown v. City of

Yakima, 116 Wn.2d 556, 561, 807 P.2d 353 (1991)). Based on our analysis ofthe

statutory language, our prior case law, and the functional differences between cities

and special purpose districts, we conclude that Proposition 1 can be harmonized with

RCW 14.08.330 because the Port of Seattle does not show that Proposition 1 would

interfere with airport operations. Therefore, we hold that Proposition 1 can be applied

at the Seattle-Tacoma International Airport.