Deputy Sheriff's Ass'n v. Board of Commissioners for Yakima County

601 P.2d 936, 92 Wash. 2d 831, 1979 Wash. LEXIS 1448, 103 L.R.R.M. (BNA) 2585
CourtWashington Supreme Court
DecidedOctober 25, 1979
Docket46019
StatusPublished
Cited by88 cases

This text of 601 P.2d 936 (Deputy Sheriff's Ass'n v. Board of Commissioners for Yakima County) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Deputy Sheriff's Ass'n v. Board of Commissioners for Yakima County, 601 P.2d 936, 92 Wash. 2d 831, 1979 Wash. LEXIS 1448, 103 L.R.R.M. (BNA) 2585 (Wash. 1979).

Opinions

[833]*833Brachtenbach, J.

This case concerns the applicability of certain provisions of the Public Employees' Collective Bargaining Act (PECBA), RCW 41.56, to Yakima County deputy sheriffs. Some background is necessary to put the precise issue in context.

PECBA was enacted in 1967, as then-Governor Evans explained when executing a partial veto,

to promote the continued improvement of the relationship between public employers and their employees by providing a uniform basis for implementing the right of public employees to join labor organizations of their own choosing and to be represented by such organizations in matters concerning their employment relations with public employers.

Laws of 1967, 1st Ex. Sess., ch. 108, p. 1891. In 1973, the Act was amended 4n part by the addition of provisions for mandatory mediation, fact-finding and binding arbitration for "uniformed personnel." RCW 41.56.030(6); .430-.490; .905; .910.

"Uniformed personnel" are defined by RCW 41.56.030(6) as "law enforcement officers ... of cities with a population of fifteen thousand or more or law enforcement officers employed by the governing body of AA counties". An AA county has a population of 500,000 or more. RCW 36.13-.010. King County is currently this state's only AA county. A first class county has a population of 125,000 but less than 210,000. RCW 36.13.010. Yakima County fits in this category.

The Yakima County Deputy Sheriff's Association (deputy sheriffs) brought this declaratory action to challenge as unconstitutionally underinclusive RCW 41.56.030(6)'s classification of "uniformed personnel" by population. The trial court held that the deputy sheriffs' equal protection rights were violated by RCW 41.56.030(6)'s population classification. It then struck the challenged language from the statute, thereby extending the act to all law enforcement personnel. We accepted direct review under RAP 4.2.

[834]*834The precise issue here, therefore, is whether the exclusion of non-AA county deputy sheriffs from PECBA's mandatory mediation, fact-finding and arbitration provisions violates the Equal Protection Clause of the federal Fourteenth Amendment and the Privileges and Immunities Clause of the state constitution (Const, art. 1, § 12). We hold that it does not and reverse.

We begin by ascertaining the challenged legislative classification. RCW 41.56.030(6) creates a class of "uniformed personnel", i.e., law enforcement officers employed by AA counties or cities with at least a 15,000 population. Thus, the challenged class in this lawsuit is that of law enforcement officers statutorily designated as "uniformed personnel." Respondent deputy sheriffs are law enforcement officers outside this class.

The deputy sheriffs do not contend, nor did the trial court find, that the deputies are part of a suspect class or that they have a fundamental right to mandatory mediation, fact-finding and arbitration. Therefore, we examine the legislature's decision to classify certain law enforcement officers as "uniformed personnel" with minimal rather than strict scrutiny. Nielsen v. Washington State Bar Ass'n, 90 Wn.2d 818, 820, 585 P.2d 1191 (1978).

There is some confusion in our cases about the requirements of minimal scrutiny. In some cases, we seem only to examine whether the challenged classification rests upon grounds that reasonably constitute a distinction between those within and without the class. State v. Ruzicka, 89 Wn.2d 217, 231, 570 P.2d 1208 (1977); In re Ballot Title for Initiative 333, 88 Wn.2d 192, 194, 558 P.2d 248, 559 P.2d 562 (1977); Gluck v. Employment Security Dep’t, 84 Wn.2d 316, 318, 525 P.2d 768 (1974). In other cases, we seem to be concerned only that the classification have some rational relation to the legislation's purpose. Seattle v. Buchanan, 90 Wn.2d 584, 592, 584 P.2d 918 (1978); In re Patterson, 90 Wn.2d 144, 149-50, 579 P.2d 1335 (1978); Houser v. State, 85 Wn.2d 803, 807, 540 P.2d 412 (1975). Finally, in some cases, we claim to use a [835]*835"rational relationship" test, but then only look for "reasonable grounds." Willard v. Department of Social & Health Servs., 91 Wn.2d 759, 763, 592 P.2d 1103 (1979); Griffin v. Department of Social & Health Servs., 91 Wn.2d 616, 627, 590 P.2d 816 (1979); Childers v. Childers, 89 Wn.2d 592, 604-05, 575 P.2d 201 (1978).

In fact, three steps are involved when measuring the constitutionality of a legislative classification with minimal scrutiny. Underlying this scrutiny is the notion that the party challenging the classification has the heavy burden of overcoming the presumption of a statute's constitutionality. Aetna Life Ins. Co. v. Washington Life & Disability Ins. Guar. Ass'n, 83 Wn.2d 523, 528, 520 P.2d 162 (1974).

First, does the classification apply alike to all members within the designated class? In re George, 90 Wn.2d 90, 94, 579 P.2d 354 (1978); Everett v. Fire Fighters, Local 350, 87 Wn.2d 572, 576, 555 P.2d 418 (1976). The answer is usually yes. Washington Helpers Ass'n v. State, 81 Wn.2d 410, 421, 502 P.2d 1170 (1972); Belancsik v. Overlake Memorial Hosp., 80 Wn.2d 111, 115, 492 P.2d 219 (1971); State ex rel. Bacich v. Huse, 187 Wash. 75, 81, 59 P.2d 1101 (1936). However, an affirmative answer to this narrow question

does not itself mean that the challenged legislative classification will survive minimal scrutiny. See L. Tribe, American Constitutional Law 994-95 (1978); Tussman & tenBrock, The Equal Protection of the Laws, 37 Cal. L. Rev. 341, 345 (1949).

Second, does some basis in reality exist for reasonably distinguishing between those within and without the designated class? More specifically, do reasonable grounds exist to support the classification's distinction between those within and without the class? Crane Towing, Inc. v. Gorton, 89 Wn.2d 161, 174, 570 P.2d 428 (1977); Clark v. Dwyer, 56 Wn.2d 425, 435, 353 P.2d 941

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Bluebook (online)
601 P.2d 936, 92 Wash. 2d 831, 1979 Wash. LEXIS 1448, 103 L.R.R.M. (BNA) 2585, Counsel Stack Legal Research, https://law.counselstack.com/opinion/deputy-sheriffs-assn-v-board-of-commissioners-for-yakima-county-wash-1979.