Heinsma v. City of Vancouver

Summary

The Washington Supreme Court held that the City of Vancouver did not violate article XI, section 11 of the Washington Constitution by extending employee insurance benefits to domestic partners. Because RCW 41.04.180 did not define “dependents,” the city had authority to include domestic partners within that term, and the benefits program was not preempted by state regulation of marriage or familial relationships. The court affirmed summary judgment for the city.

Holdings

1. The Legislature did not expressly or impliedly preempt Vancouver from adopting a reasonable definition of dependents that included domestic partners for purposes of municipal employee benefits.
2. The City's inclusion of domestic partners as dependents did not directly and irreconcilably conflict with RCW 41.04.180.
3. The City's limited recognition of domestic partnerships for its employee-benefits program did not create the equivalent of marriage or interfere unconstitutionally with the Legislature's authority to regulate familial relationships statewide.

Questions Presented

1. Whether article XI, section 11 of the Washington Constitution preempted or prohibited Vancouver from defining dependents under RCW 41.04.180 to include domestic partners for purposes of municipal employee benefits.
2. Whether the City's inclusion of domestic partners in its employee-benefits program directly and irreconcilably conflicted with RCW 41.04.180 or other statewide laws regulating familial relationships.
3. Whether the City's recognition of domestic partnerships impermissibly created the equivalent of marriage or interfered with the Legislature's authority to regulate familial relationships statewide.

Disposition

affirmed