subject-in-title rule in Washington

2025“The title satisfies the subject in title requirement ‘if it gives notice that would lead to an inquiry into the body of the act, or 14 No. 59349-1-II indicate to an inquiring mind the scope and purpose of the law.’” Id. (quoting Young Men’s Christian Ass’n v. State, 62 Wn.2d 504, 506 , 383 P.2d 497 (1963)).

2025“The title satisfies the subject in title requirement ‘if it gives notice that would lead to an inquiry into the body of the act, or 14 No. 59349-1-II indicate to an inquiring mind the scope and purpose of the law.’” Id. (quoting Young Men’s Christian Ass’n v. State, 62 Wn.2d 504, 506 , 383 P.2d 497 (1963)).

2025Wash. State Grange, 153 Wn.2d at 497 .

2014App. 828, 834 , 142 P. 3d 641 ( 2006) ( citing Citizens for Responsible Wildlife Mgmt. v. State, 149 Wn.2d 622, 632 , 71 P. 3d 644 ( 2003)). " A party challenging the statute' s constitutionality bears the 1 To the extent that Miller argues that S. B. 6151 violates that subject -in - title rule, his argument is meritless. " The title satisfies the subject in title requirement ` if it gives notice that would lead to an inquiry into the body of the act, or indicate to an inquiring mind the scope and purpose of the law. ' Wash. State Grange v. Locke, 153 Wn.2d 475, 497 , 105 P. 3d 9 ( 2005) ( quo

2025“Any objections to a title must be grave, and the conflict between it and the constitution palpable, before we will hold an act unconstitutional for violating the subject-in-title requirement.” Pierce County,, 144 Wn.

2024“Any objections to a title must be grave, and the conflict between it and the constitution palpable, before we will hold an act unconstitutional for violating the subject-in-title requirement.” Pierce County,, 144 Wn.

2014App. 828, 834 , 142 P. 3d 641 ( 2006) ( citing Citizens for Responsible Wildlife Mgmt. v. State, 149 Wn.2d 622, 632 , 71 P. 3d 644 ( 2003)). " A party challenging the statute' s constitutionality bears the 1 To the extent that Miller argues that S. B. 6151 violates that subject -in - title rule, his argument is meritless. " The title satisfies the subject in title requirement ` if it gives notice that would lead to an inquiry into the body of the act, or indicate to an inquiring mind the scope and purpose of the law. ' Wash. State Grange v. Locke, 153 Wn.2d 475, 497 , 105 P. 3d 9 ( 2005) ( quo

2006Citizens, 149 Wn.2d at 639 (citing Amalgamated, 142 Wn.2d at 217 ). ¶31 Stannard and Stevenson argue that 1-655 violates the subject-in-title rule because the initiative’s title expresses a criminal penalty but fails to mention the corresponding administrative penalty.

2007Patrice, 136 Wn.2d at 855 .

2006The majority then compounds its error by conflating the two distinct inquiries under article II, section 19, concluding the subject-in-title analysis disposes of the multiple subject claim as well. ¶43 Article II, section 19 of the Washington Constitution provides, “[n]o bill shall embrace more than one subject, and that shall be expressed in the title.” This clause mandates two distinct prohibitions: “ ‘(1) No bill shall embrace more than one subject; and (2) the subject of every bill shall be expressed in the title.’ ” Patrice v. Murphy, 136 Wn.2d 845, 852 , 966 P.2d 1271 (1998) (quoting Sta

2012Wash. Fed'n of State Emps., 127 Wash.2d at 553-54 , 901 P.2d 1028 . ¶ 26 There are two distinct prohibitions in article II, section 19:(1) the single-subject rule and (2) the subject-in-title rule.

2003As with the single-subject requirement, the subject-in-title requirement of article II, section 19 "is to be liberally construed in favor of the legislation." Wash. Fed'n, 127 Wash.2d at 555 , 901 P.2d 1028 .

2019The subject in title requirement is to be liberally construed in favor of the constitutionality of the legislation. ~ “Any ‘objections to the title must be grave and the conflict between it and the constitution palpable before we will hold an act unconstitutional.” j4~ (quoting Wash. Ass’n of Neighborhood Stores v. State, 149 Wn2d 359, 372, 70 P.3d 920 (2003)).

2012Any "`objections to the title must be grave and the conflict between it and the constitution palpable before we will hold an act unconstitutional.'" Wash. Ass'n of Neighborhood Stores v. State, 149 Wash.2d 359, 372 , 70 P.3d 920 (2003) (internal quotation marks omitted) (quoting Nat'l Ass'n of Creditors v. Brown, 147 Wash. 1, 3 , 264 P. 1005 (1928)). ¶ 42 As an initial matter, intervenors assert that the pre-election review under RCW 29A.72.080 was the appropriate proceeding for appellants to challenge I-1183's *643 title and that appellants are now precluded from raising a subject-in-title ch

2007Patrice, 136 Wash.2d at 855 , 966 P.2d 1271 .

2006The majority then compounds its error by conflating the two distinct inquiries under article II, section 19, concluding the subject-in-title analysis disposes of the multiple subject claim as well. ¶43 Article II, section 19 of the Washington Constitution provides, “[n]o bill shall embrace more than one subject, and that shall be expressed in the title.” This clause mandates two distinct prohibitions: “ ‘(1) No bill shall embrace more than one subject; and (2) the subject of every bill shall be expressed in the title.’ ” Patrice v. Murphy, 136 Wn.2d 845, 852 , 966 P.2d 1271 (1998) (quoting Sta

2014App. 828, 834 , 142 P. 3d 641 ( 2006) ( citing Citizens for Responsible Wildlife Mgmt. v. State, 149 Wn.2d 622, 632 , 71 P. 3d 644 ( 2003)). " A party challenging the statute' s constitutionality bears the 1 To the extent that Miller argues that S. B. 6151 violates that subject -in - title rule, his argument is meritless. " The title satisfies the subject in title requirement ` if it gives notice that would lead to an inquiry into the body of the act, or indicate to an inquiring mind the scope and purpose of the law. ' Wash. State Grange v. Locke, 153 Wn.2d 475, 497 , 105 P. 3d 9 ( 2005) ( quo

2006Citizens, 149 Wash.2d at 639 , 71 P.3d 644 (citing Amalgamated, 142 Wash.2d at 217 , 11 P.3d 762 ). ¶ 31 Stannard and Stevenson argue that I-655 violates the subject-in-title rule because the initiative's title expresses a criminal penalty but fails to mention the corresponding administrative penalty.

2012Any “ ‘objections to the title must be grave and the conflict between it and the constitution palpable before we will hold an act unconstitutional.’ ” Wash. Ass’n of Neighborhood Stores v. State, 149 Wn.2d 359, 372 , 70 P.3d 920 (2003) (internal quotation marks omitted) (quoting Nat’l Ass’n of Creditors v. Brown, 147 Wash. 1, 3 , 264 P. 1005 (1928)). ¶44 As an initial matter, intervenors assert that the pre-election review under RCW 29A.72.080 was the appropriate proceeding for appellants to challenge I-1183’s title and that appellants are now precluded from raising a subject-in-title challeng

2012Any "`objections to the title must be grave and the conflict between it and the constitution palpable before we will hold an act unconstitutional.'" Wash. Ass'n of Neighborhood Stores v. State, 149 Wash.2d 359, 372 , 70 P.3d 920 (2003) (internal quotation marks omitted) (quoting Nat'l Ass'n of Creditors v. Brown, 147 Wash. 1, 3 , 264 P. 1005 (1928)). ¶ 42 As an initial matter, intervenors assert that the pre-election review under RCW 29A.72.080 was the appropriate proceeding for appellants to challenge I-1183's *643 title and that appellants are now precluded from raising a subject-in-title ch

2012Id. at 623-24 , 110 P.2d 627 .

2012Id. at 623-24 , 110 P.2d 627 .

2025State v. Alexander, 184 Wn.

2024State v. Alexander, 184 Wn.

2014App. 828, 834 , 142 P. 3d 641 ( 2006) ( citing Citizens for Responsible Wildlife Mgmt. v. State, 149 Wn.2d 622, 632 , 71 P. 3d 644 ( 2003)). " A party challenging the statute' s constitutionality bears the 1 To the extent that Miller argues that S. B. 6151 violates that subject -in - title rule, his argument is meritless. " The title satisfies the subject in title requirement ` if it gives notice that would lead to an inquiry into the body of the act, or indicate to an inquiring mind the scope and purpose of the law. ' Wash. State Grange v. Locke, 153 Wn.2d 475, 497 , 105 P. 3d 9 ( 2005) ( quo

2012Wash. State Grange v. Locke, 153 Wash.2d 475, 495 , 105 P.3d 9 (2005).

2012Wash. Toll Bridge Auth. v. Yelle, 32 Wash.2d 13, 24-25 , 200 P.2d 467 (1948) (one purpose of the subject-in-title rule is to prevent surprise or fraud).

2012Wash. Toll Bridge Auth. v. Yelle, 32 Wash.2d 13, 24-25 , 200 P.2d 467 (1948) (one purpose of the subject-in-title rule is to prevent surprise or fraud).

2020For the purpose of a subject-in-title analysis, “a title complies with the constitution if it gives notice that would lead to an inquiry into the body of the act, or indicate to an inquiring mind the scope and purpose of the law.” Young Men’s Christian Ass’n v. State, 62 Wn.2d 504, 506 , 383 P.2d 497 (1963); ATU, 142 Wn.2d at 217 . “ʻThe title to a bill need not be an index to its contents; nor is the title expected to give the details contained in the bill.’” Wash. Fed’n, 127 Wn.2d at 555 (quoting Treffry v. Taylor, 67 Wn.2d 487, 491 , 408 P.2d 269 (1965)).

2020For the purpose of a subject-in-title analysis, “a title complies with the constitution if it gives notice that would lead to an inquiry into the body of the act, or indicate to an inquiring mind the scope and purpose of the law.” Young Men’s Christian Ass’n v. State, 62 Wn.2d 504, 506 , 383 P.2d 497 (1963); ATU, 142 Wn.2d at 217 . “ʻThe title to a bill need not be an index to its contents; nor is the title expected to give the details contained in the bill.’” Wash. Fed’n, 127 Wn.2d at 555 (quoting Treffry v. Taylor, 67 Wn.2d 487, 491 , 408 P.2d 269 (1965)).

2012Power, Inc. v. Huntley, 39 Wash.2d 191, 198 , 235 P.2d 173 (1951). "`[A] title complies with the constitution if it gives notice that would lead to an inquiry into the body of the act, or indicate to an inquiring mind the scope and purpose of the law.'" Wash. Fed'n of State Emps., 127 Wash.2d at 555 , 901 P.2d 1028 (alteration in original) (quoting Young Men's Christian Ass'n v. State, 62 Wash.2d 504, 506 , 383 P.2d 497 (1963)).

2012Power, Inc. v. Huntley, 39 Wash.2d 191, 198 , 235 P.2d 173 (1951). "`[A] title complies with the constitution if it gives notice that would lead to an inquiry into the body of the act, or indicate to an inquiring mind the scope and purpose of the law.'" Wash. Fed'n of State Emps., 127 Wash.2d at 555 , 901 P.2d 1028 (alteration in original) (quoting Young Men's Christian Ass'n v. State, 62 Wash.2d 504, 506 , 383 P.2d 497 (1963)).

2012Any "`objections to the title must be grave and the conflict between it and the constitution palpable before we will hold an act unconstitutional.'" Wash. Ass'n of Neighborhood Stores v. State, 149 Wash.2d 359, 372 , 70 P.3d 920 (2003) (internal quotation marks omitted) (quoting Nat'l Ass'n of Creditors v. Brown, 147 Wash. 1, 3 , 264 P. 1005 (1928)). ¶ 42 As an initial matter, intervenors assert that the pre-election review under RCW 29A.72.080 was the appropriate proceeding for appellants to challenge I-1183's *643 title and that appellants are now precluded from raising a subject-in-title ch

2012Any "`objections to the title must be grave and the conflict between it and the constitution palpable before we will hold an act unconstitutional.'" Wash. Ass'n of Neighborhood Stores v. State, 149 Wash.2d 359, 372 , 70 P.3d 920 (2003) (internal quotation marks omitted) (quoting Nat'l Ass'n of Creditors v. Brown, 147 Wash. 1, 3 , 264 P. 1005 (1928)). ¶ 42 As an initial matter, intervenors assert that the pre-election review under RCW 29A.72.080 was the appropriate proceeding for appellants to challenge I-1183's *643 title and that appellants are now precluded from raising a subject-in-title ch

2012Seymour, 6 Wash. at 148-49 , 32 P. 1077 ; Howlett, 17 Wash. at 635 , 50 P. 522 .

2012Seymour, 6 Wash. at 148-49 , 32 P. 1077 ; Howlett, 17 Wash. at 635 , 50 P. 522 .

2006In Keeting v. Public Utility District No. 1 of Clallam County, 49 Wn.2d 761, 764 , 306 P.2d 762 (1957), the single-subject inquiry was framed as whether “the [original and amendatory] acts embrace more than one subject.” The court appeared to conclude that the amendatory act’s changes in the original law constituted a single subject because they “related to the single subject” expressed in the original act’s title.

2006In Keeting v. Public Utility District No. 1 of Clallam County, 49 Wn.2d 761, 764 , 306 P.2d 762 (1957), the single-subject inquiry was framed as whether “the [original and amendatory] acts embrace more than one subject.” The court appeared to conclude that the amendatory act’s changes in the original law constituted a single subject because they “related to the single subject” expressed in the original act’s title.

2006In Goodnoe Hills School District No. 24 v. Forry, 52 Wn.2d 868, 329 P.2d 1083 (1958), the court noted the appellants’ contention that an amendatory act violated article II, section 19 and their “argu[ment] that included within [the amendatory act’s] title are two subjects.” Id. at 873 .

2006In Goodnoe Hills School District No. 24 v. Forry, 52 Wn.2d 868, 329 P.2d 1083 (1958), the court noted the appellants’ contention that an amendatory act violated article II, section 19 and their “argu[ment] that included within [the amendatory act’s] title are two subjects.” Id. at 873 .

2006See Seattle Elec., 28 Wash. at 325-26 , 68 P. 957 ; Fray, 134 Wash.2d at 654-55 , 952 P.2d 601 (reaffirming that the "`mere reference to a section in the title of an act does not state a subject'" (quoting Seattle Elec., 28 Wash. at 325 , 68 P. 957 )); State v. Thomas, 103 Wash. App. 800, 808 , 14 P.3d 854 (2000) (defining the relevant title as "the word, phrase, or phrases following `AN ACT Relating to ...' and preceding the first semicolon"). ¶ 37 SHB 3055's Compliance with Article II, Section 19.

2006See Seattle Elec., 28 Wash. at 325-26 ; Fray, 134 Wn.2d at 654-55 (reaffirming that the “ ‘mere reference to a section in the title of an act does not state a subject’ ” (quoting Seattle Elec., 28 Wash. at 325 )); State v. Thomas, 103 Wn.

2005The majority would do well to remember its own exhortation: “A court should ‘not strain to interpret [a] statute as constitutional: a plain reading must make the interpretation reasonable.’ ” Amalgamated Transit, 142 Wn.2d at 225 (alteration in original) (quoting Soundgarden v. Eikenberry, 123 Wn.2d 750, 757 , 871 P.2d 1050 (1994)).

2005The majority would do well to remember its own exhortation: “A court should ‘not strain to interpret [a] statute as constitutional: a plain reading must make the interpretation reasonable.’ ” Amalgamated Transit, 142 Wn.2d at 225 (alteration in original) (quoting Soundgarden v. Eikenberry, 123 Wn.2d 750, 757 , 871 P.2d 1050 (1994)).