Heinsma v. City of Vancouver, 144 Wash. 2d 556

Summary

The Supreme Court of Washington held that the City of Vancouver's domestic partner benefits program did not violate article XI, section 11 of the Washington Constitution or conflict with RCW 41.04.180. The court concluded that the legislature had not preempted the city from defining dependents for its employee benefits program and that recognizing domestic partners for this limited purpose was a local matter. A dissent argued that the program impermissibly extended benefits to persons who were not statutory dependents.

Holdings

1. RCW 41.04.180 did not expressly or impliedly preempt the City of Vancouver from defining who qualifies as a dependent for purposes of municipal employee benefits.
2. The City's inclusion of domestic partners as dependents was consistent with the statute and did not directly and irreconcilably conflict with RCW 41.04.180.
3. The City's limited recognition of domestic partnerships for employee benefits did not interfere with the State's authority to regulate marriage and familial relationships.

Questions Presented

1. Whether article XI, section 11 of the Washington Constitution or state law preempted the City of Vancouver from defining dependents for its employee benefits program to include domestic partners.
2. Whether the City's inclusion of domestic partners in the term dependents directly and irreconcilably conflicted with RCW 41.04.180.
3. Whether the City's limited recognition of domestic partnerships for employee benefits impermissibly interfered with the State's authority to regulate marriage and familial relationships.

Disposition

affirmed