Washington Federation of State Employees v. State

(concurring in part/dissenting in part) — I concur in the majority’s view that art. II, § 19 of the Washington Constitution applies to initiative measures such as Initiative 134. I write separately to emphasize my concern that this court’s treatment of art. II, § 19 cases has too often been a talismanic recitation of the "rational unity” doctrine without a real discussion of what that doctrine means. This lack of a real standard is frustrating for legislators and the public alike.

I disagree with the majority’s decision on the scope of remand, believing that the court should reverse the trial…