1191 Secondmenue. Suite 2000

FAG. F. CA 

LAW GROUP

Matthew J. Segal


 

Jessica A. Skelton
Jessica. 

VIA FED EX AND E-MAIL

November 8, 2019

The Honorable Bob Ferguson
Attorney General of Washington
1125 Washington Street SE

PO. Box 40100

Olympia, WA 98504-0100

Re: Request for the Attorney General to Investigate and Institute Legal Proceedings on
the Unconstitutionality of Initiative Measure N0. 976

Dear Mr. Attorney General:

We represent a group of Washington taxpayers as well as organizations and entities with
taxpayer members and constituents. We request that your office investigate and 
institute legal proceedings to remedy the constitutional violations arising from Initiative Measure
No. 976 

I-976 violates the Washington Constitution on multiple grounds, including but not limited to the
following:

First, I-976 violates the single-subj ect requirement in article 11, section 19 of the Washington
Constitution. The initiative contains numerous unrelated subjects joined together in a blatant
attempt at unlawful ?logrolling?.

Second, I-976 violates the subj ect?in-title requirement in article II, section 19 of the Washington
Constitution. There is no reference in the I-976 ballot title to many of the subjects within the
initiative. Additionally, the title misleadingly suggests that voters will retain the authority to
approve vehicle charges, but several provisions of I-976 then repeal statutes that provide for
voter-approved charges.

Attorney General Ferguson
November 8, 2019
Page 2

Third, 1-976 violates article 11, section 37 of the Washington Constitution because it improperly
amends or attempts to amend existing law without setting forth the amendments in full.

Fourth, 1-976 violates home rule principles in the Washington Constitution, including the
provision in article XI, section 12 that prohibits the state Legislature from imposing local taxes
for local matters.

Fifth, 1-976 violates article 11, section 1 of the Washington Constitution because it exceeds the
scope of the initiative power.

Sixth, 1-976 violates article 1, section 23 of the Washington Constitution in that it impairs
multiple preexisting bond and other contracts.

In sum, 1-976 is an unconstitutional law designed to mislead voters about its actual provisions
and to interfere with funding mechanisms and projects previously approved by local
governments and/or voters. We therefore request that you pursue immediate measures to address
the unconstitutional provisions of 1-976.

ayer to demand that the Attorney General bring suit on behalf of all
taxpayers).

Please let us know at your earliest convenience whether your of?ce will initiate legal
proceedings against 1-976.

Sincerely yours,

PACIFICA LAW GROUP LLP

 2

Matthew J. Segal
Jessica A. Skelton

cc: Noah Purcell, Solicitor General for the Washington State Attorney General?s Of?ce