Staples v. Benton County

151 Wash. 2d 460
CourtWashington Supreme Court
DecidedMay 13, 2004
DocketNo. 74325-8
StatusPublished
Cited by6 cases

This text of 151 Wash. 2d 460 (Staples v. Benton 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
Staples v. Benton County, 151 Wash. 2d 460 (Wash. 2004).

Opinions

Johnson, J.

This case involves a claim brought by former Superior Court Judge Fred R. Staples, who is seeking a judicial determination that Benton County has unlawfully moved certain offices of county government from the city of Prosser to the city of Kennewick in violation of article XI, section 2 of the Washington State Constitution. Staples filed a petition for writ of mandamus with the trial court, directing the county commissioner to move the county offices that are located at the justice center in Kennewick back to the county seat in Prosser. The trial court held there was no state constitutional violation and dismissed Staples’ petition. We affirm and hold that a writ of mandamus is not an available remedy in this case.

FACTUAL AND PROCEDURAL HISTORY

Since 1905, the city of Prosser has been the county seat of Benton County. In 1926, the Benton County courthouse was erected in Prosser and has been maintained and expanded since that date. In 1980, we approved an order entered at the request of Benton County Superior Court judges who sought permission to conduct trial court proceedings outside the county seat of Prosser in conjunction with the construction of a new justice center in Kennewick. Clerk’s Papers (CP) at 60. The order authorized the Benton County [463]*463Superior Court to exercise its discretion to hold sessions at the justice center upon the facility’s completion.1

On February 3, 2003, Staples filed a petition for writ of mandamus in the Benton County Superior Court to compel Benton County to move its offices of county government from the justice center in Kennewick back to the county seat in Prosser. CP at 7. He named the county and three members of the county’s board of commissioners as defendants. CP at 87, 89. Staples contends that these parties have removed the county seat in violation of article XI, section 2 of the Washington State Constitution by maintaining the law and justice functions of county government in Kennewick. CP at 7. The provision states that:

No county seat shall be removed unless three-fifths of the qualified electors of the county, voting on the proposition at a general election shall vote in favor of such removal, and three-fifths of all votes cast on the proposition shall be required to relocate a county seat. A proposition of removal shall not be submitted in the same county more than once in four years.

Const, art. XI, § 2.

In June 2003, the parties filed cross-motions for summary judgment. The trial court entered an order denying Staples’ cross-motion for summary judgment, granting the county’s cross-motion for summary judgment, and dismissing Staples’ petition for writ of mandamus.

We granted direct review of the trial court’s decision. Staples maintains that certain functions of county government, particularly the law and justice functions,2 have [464]*464operated outside the county seat of Prosser for the last 20 years in violation of article XI, section 2. Statement for Direct Review at 1. Staples specifically seeks a writ of mandamus compelling the county to move the county offices of government from the justice center in Kennewick back to the county seat in Prosser. Appellant’s Br. at 7.

The issues we must resolve, then, are (1) whether Benton County maintains certain offices of county government at the justice center in Kennewick in violation of article XI, section 2; and (2) whether a writ of mandamus is an available remedy in this case.

ANALYSIS

Mandamus is an extraordinary writ, the issuance of which is not mandatory, even in response to allegations of constitutional violations. See Walker v. Munro, 124 Wn.2d 402, 407, 879 P.2d 920 (1994). We have nonexclusive and discretionary jurisdiction to issue a writ of mandamus. Const, art. IV, § 4. We will issue a writ of mandamus only in cases where there is no plain, speedy, and adequate remedy at law. RCW 7.16.170. For example, we will issue a writ of mandamus to compel the performance of an act or duty expressly required by law. Cedar County Comm. v. Munro, 134 Wn.2d 377, 380-81, 950 P.2d 446 (1998).

Staples seeks a writ of mandamus against the county and three members of its board of commissioners to compel the county to move its offices of county government from the justice center in Kennewick back to the county seat in Prosser.3 Staples contends that, by maintaining the law and justice functions of government at the justice center, the county has shifted the county seat from Prosser to Kennewick in violation of article XI, section 2.

[465]*465The problem with Staples’ argument is that the record reflects that the offices of county government are still located in Prosser. The county seat itself has not moved. Rather, portions of, if not the majority of, the law and justice functions of government have been established outside Prosser at the justice center in Kennewick. The county seat consists of more than just the law and justice functions of government. Also, the record establishes that county officials consider Prosser as the county seat.4 As such, the wholesale removal of all the functions of county government has not occurred that would involve the requirements of article XI, section 2.

No constitutional provision exists that prevents counties from locating government offices outside a county seat. The location of county offices is governed by various statutes.5 Staples does not base his petition for writ of mandamus on the violation of these statutes, but on a violation of article XI, section 2.

[466]*466We first recognized that the location of county offices is controlled by statutes and not article XI, section 2, or any other provision of the Washington State Constitution, in State ex rel. Becker v. Wiley, 16 Wn.2d 340, 133 P.2d 507 (1943). In Wiley, 16 Wn.2d 340, we held that county commissioners and the prosecuting attorney are within their statutory authority to maintain offices outside the county seat. In doing so, we analyzed the law pertaining to the location of county offices and did not refer to article XI, section 2 of the Washington State Constitution.

This approach is also consistent with our most recent decision in Thurston County ex rel. Bd. of County Comm’rs v. City of Olympia, 151 Wn.2d 171, 86 P.3d 151 (2004). In that case, Thurston County wanted to move its entire superior court functions outside the county seat of Olympia to the city of Tumwater, which would have violated RCW 2.08.030.6 We held that the county cannot legally move its courts and other law and justice facilities outside the county seat of Olympia because statutory authority requires certain offices of county government to be located “at the county seat,” which means “in” the county seat.

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Bluebook (online)
151 Wash. 2d 460, Counsel Stack Legal Research, https://law.counselstack.com/opinion/staples-v-benton-county-wash-2004.