Summary
The Washington Supreme Court reviewed consolidated challenges to the Washington Department of Social and Health Services' determination that two children with serious orthopedic conditions were no longer eligible for developmental-disability services after reaching age six. The court held that the governing statute and administrative rule properly limited eligibility to developmental disabilities involving cognitive or intellectual impairment or specified related conditions, and that the rule was within the Department's delegated authority. The court also rejected federal preemption and equal-protection challenges, affirmed the judgment in Campbell, and reversed the judgment in Hurd.
Holdings
- WAC 388-825-030 is within the Department's delegated authority because it is reasonably consistent with RCW 71A.10.020(3). The statute limits qualifying conditions to specified conditions and neurological or other conditions closely related to mental retardation or requiring similar treatment; it does not encompass orthopedic medical conditions without cognitive or intellectual impairment.
- The claimants failed to establish that federal law preempted Washington's definition of developmental disability.
- WAC 388-825-030(6)(c)'s distinction between children under six and children age six or older survives rational-basis review and does not violate equal protection.
- Equitable estoppel did not apply because the Department made no inconsistent representation, Carmen's mother could not establish justifiable reliance, and injury was not proven by clear, cogent, and convincing evidence.
Questions Presented
- Whether WAC 388-825-030 exceeded the Department's delegated authority by limiting developmental-disability eligibility to conditions involving cognitive or intellectual impairment or conditions similar to mental retardation.
- Whether federal law preempted Washington's definition of developmental disability because some Department services could receive federal funding.
- Whether RCW 71A.10.020(3) and WAC 388-825-030 violated equal protection by treating children under six differently from children age six and older.
- Whether the Department was equitably estopped from terminating Carmen Campbell's eligibility after previously providing services.
Disposition
other
Cases Cited (23)
- Postema v. Pollution Control Hr’gs Bd., 142 Wn.2d 68, 100, 11 P.3d 726 (2000)(followed)
- Hilltop Terrace Homeowner’s Ass’n v. Island County, 126 Wn.2d 22, 30, 891 P.2d 29 (1995)(followed)
- State v. Brown, 142 Wn.2d 57, 62, 11 P.3d 818 (2000)(followed)
- Fahn v. Cowlitz County, 93 Wn.2d 368, 374, 610 P.2d 857, 621 P.2d 1293 (1980)(followed)
- State v. J.M., 144 Wn.2d 472, 480, 28 P.3d 720 (2001)(followed)
- In re Elec. Lightwave, Inc., 123 Wn.2d 530, 536, 869 P.2d 1045 (1994)(followed)
- City of Seattle v. Burlington N. R.R., 145 Wn.2d 661, 667, 41 P.3d 1169 (2002)(followed)
- Stevedoring Servs. of Am., Inc. v. Eggert, 129 Wn.2d 17, 24, 914 P.2d 737 (1996)(followed)
- US West Communications, Inc. v. Utils. & Transp. Comm’n, 134 Wn.2d 48, 56, 72, 949 P.2d 1321 (1997)(followed)
- Waste Mgmt. of Seattle, Inc. v. Utils. & Transp. Comm’n, 123 Wn.2d 621, 633, 869 P.2d 1034 (1994)(followed)
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Court Document
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