Washington State Grange v. Locke

fl In 2003, the Ninth Circuit Court of Appeals held that Washington’s blanket primary system was unconstitutional.1 As a result, the Washington legislature was required to enact a new system for conducting primary elections in Washington, and during the 2004 session, the legislature responded by enacting Engrossed Senate Bill 6453 (ESB 6453), adopting the “Louisiana style” or “top two” primary system in Washington. ESB 6453 also allowed for implementation of a “Montana style” primary *479system as an alternative, should the Louisiana system be overturned by the courts.2 Governor Locke then vetoed…