Wash. Supreme Court published opinion — 961328.pdf

Citation: Wash. Supreme Court published opinion — 961328.pdf
Jurisdiction: Washington (state)
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Original Source: https://www.courts.wa.gov/opinions/pdf/961328.pdf ↗

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For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Woods v. Seattle’s Union Gospel Mission, 96132-8
(Stephens, J., dissenting in part and concurring in part)

grounds standard—a heightened standard of review—devolving into rational basis

review.

Indeed, the majority’s reasoning appears to be circular by gleaning the

legislature’s goal or purpose from the legislative distinction itself. See majority at

11 (noting that “RCW 49.60.040(11) itself is evidence of reasonable grounds”). But

we do not analyze reasonable grounds as a syllogism (i.e., legislative distinctions

encompass legislative goals; the religious nonprofit exemption here is a legislative

distinction; thus, the religious nonprofit exemption encompasses a legislative goal).

The reasonable grounds test would be a pointless exercise if that were the case, a

tautology. Instead, we look at the broader goal or purpose of the statutory scheme.

State ex rel. Bacich, 187 Wash. at 84 (determining the distinction must bear a true

“relation to the subject matter of the act” (emphasis added)). Here, the law against

discrimination’s goal or purpose is just that: antidiscrimination. See generally RCW

49.60.010. The question thus becomes whether exempting religious nonprofits in

fact serves the legislature’s antidiscrimination goal. It does not. The legislative

distinction here is antithetical to WLAD’s stated goal or purpose because it gives

religious nonprofits carte blanche to discriminate in employment.

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For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Woods v. Seattle’s Union Gospel Mission, 96132-8
(Stephens, J., dissenting in part and concurring in part)

Despite bearing no relationship to WLAD’s purpose, the majority argues