Pierce County v. State, 150 Wash. 2d 422

Summary

The Washington Supreme Court reviewed a challenge to Initiative 776, which capped motor vehicle license tab fees at $30 and repealed certain local vehicle taxes and fees. The court held that the initiative satisfied the constitutional single-subject and subject-in-title requirements and did not substantially impair King County’s contractual obligations to bondholders. It reversed the superior court’s grant of summary judgment and remanded for further proceedings.

Holdings

1. Initiative 776 embraced a single subject because its operative provisions were rationally related to limiting state and local government charges imposed on motor vehicles. Nonbinding policy expressions did not constitute additional subjects under article II, section 19.
2. The ballot title adequately expressed Initiative 776's single subject and satisfied article II, section 19.
3. Initiative 776 did not substantially impair King County's contractual obligations to its bondholders and therefore did not violate article I, section 23.
4. Initiative 776 did not violate Washington constitutional principles of local home rule.
5. Initiative 776 did not exceed the scope of the people's initiative power because it repealed a general legislative law rather than controlling an administrative act of Sound Transit.
6. Sound Transit and its constituents had no vested property right in completion of the transit project that was deprived by Initiative 776, so the initiative did not violate due process.
7. Salish was not entitled to attorney fees under the common-fund principle.

Questions Presented

1. Whether Initiative 776 violated article II, section 19 of the Washington Constitution by embracing more than one subject.
2. Whether the initiative's ballot title adequately expressed its subject under article II, section 19.
3. Whether repeal of the local vehicle license fee and motor vehicle excise tax substantially impaired King County's contractual obligations to bondholders under article I, section 23.
4. Whether Initiative 776 violated constitutional principles of local home rule under article XI, sections 4 and 12.
5. Whether repeal of the motor vehicle excise tax exceeded the scope of the people's initiative power or violated Sound Transit's due process rights.
6. Whether Salish Village Home Owners Association was entitled to attorney fees.

Disposition

reversed_and_remanded