I.   BRIEF OF RESPONDENT IS UNTIMELY AND SHOULD BE STRICKEN

            On September 20, 2002, as required by the Order Setting Case Schedule entered in this appeal, the appellant attended the readiness conference.  He had previously and timely filed and served upon the respondent his Brief of Appellant and his Declaration by Roger W. Knight re Transcript of Proceedings Below with his transcripts of the relevant portions of the hearings below attached as Exhibits.  No attorney representing the City of Mercer Island attended the readiness conference.  During the readiness conference this Court entered the Order Setting RALJ Oral Argument.  This Order provides that the Brief of Respondent is due October 18, 2002.  On October 29, 2002, attorney William C. Coats, served by facsimile, the Brief of Respondent City of Mercer Island upon Roger W. Knight, the appellant.

            At this time, the appellant does not know whether this Brief of Respondent was filed in this Court or whether a copy has been made available to Judge Michael Trickey.

            If it has been filed with this Court, it should be stricken as untimely.  The City of Mercer Island presents no valid reason or excuse for its failure to timely prepare and file its brief and it never made any motion for any continuance in the case schedule.  Mr. Knight complied with the case schedule and he withdrew his motion for new trial when he was made aware that the compact disks containing the electronic record were finally available, solving that problem.  The late service of this Brief, after the date set for the Reply Brief in the Order Setting RALJ Oral Argument, has forced the appellant to draft, at the last minute, a Reply Brief of Appellant, at a time he was expecting to rest and prepare for oral argument.  This Reply Brief thus submitted at the Oral Argument hearing, is necessarily a rough draft.

II.  ISSUES RAISED IN THE BRIEF OF RESPONDENT

            The Brief of Respondent raises three arguments: 1) that there was no violation of the due process right to notice and opportunity to be heard; 2) due process violation was harmless error; and 3) the trial court was collaterally estopped from considering any challenge to the validity of the WorkFirst Act by the two civil cases previously litigated by Mr. Knight in this Court wherein he challenged the WorkFirst Act as a multi-subject bill prohibited by Article II Section 19 of the Washington Constitution.

            These issues are dealt with in this Reply Brief below.  City’s Issues 1) and 2) are two sides of the same coin.  The collateral estoppel issues are addressed separately below.

III.  DUE PROCESS, NOTICE AND OPPORTUNITY TO BE HEARD, FAILURE TO COMPLY WITH STATUTORY REQUIREMENT FOR SERVICE IS NOT HARMLESS ERROR

 

            In terms of Article I Section 3 of the Washington Constitution and the Fourteenth Amendment, the City might have a reasonable argument.  But the arguments presented by Mr. Knight in the trial court and in his opening Brief, pp. 5-16 are based upon statute in addition to the constitutional provisions.  RCW 74.20A.320(1) explicitly provides that one of two types of service, registered mail with return receipt signed or failing that, personal service, be accomplished before the Department of Social and Health Services (DSHS) acquires the necessary jurisdiction to certify noncompliance of a support order to the Department of Licensing (DOL).  No evidence that either of these types of service was presented in the trial court because the trial court found it lacked jurisdiction to consider this issue.

            However, a court always has jurisdiction to consider whether another court or an agency ever acquired the necessary in personum jurisdiction by means of statutorily adequate service.  There is no question that absent the WorkFirst Act and its RCW 74.20A.320, there is no statutory authorization for the DSHS to certify noncompliance with a support order to the DOL, and no statutory authority for the DOL to suspend a license on the basis of noncompliance with a support order.  Therefore, if the requirements for service set forth in RCW 74.20A.320 are not met, then neither the DSHS nor the DOL had any statutory authority to suspend the licenses of the appellant on the basis of noncompliance with a support order.

            The Supreme Court of Washington has recently reaffirmed the doctrine that what the Legislature actually included in a statute and what it actually excluded control the application of the statute.  State v. Glas, (September 19, 2002) ____ Wash. 2d. ____ found:

            To ascertain legislative intent, a court will first turn to the plain language of the statute.  State v. Reding, 119 Wn.2d 685, 690,

 835 P.3d 1019 (1992).  If the statute is unambiguous, as it is here, it is not subject to judicial interpretation and its meaning is derived

 from its language alone.  State v. Chester, 133 Wn.2d 15, 21, 940 P.2d 1374 (1997). The voyeurism statute protects an individual

 'while the person . . . is in a place where he or she would have a reasonable expectation of privacy.' RCW 9A.44.115(2) (emphasis

 added).  Grammatically, it does not make sense to apply this statement to a part of a person's body.  It is the person who is in the place,

 not a part of the person.  The two categories of private places modify and define the place where a person may have a reasonable

 expectation of privacy.  Thus, each subsection relates to the place where the person is located (i.e., where the person is 'in').  Thus, it is

 the physical location of the person that is ultimately at issue, not the part of the person's body.

 

As offensive as Mr. Glas’ actions may have been, the Legislature has to specifically prohibit such actions in a criminal statute in a manner that is not “void for vagueness” for him to be guilty of any crime.  Similarly, In re Personal Restraint of Andress, (October 24, 2002) _____ Wash. 2d. _____ found that when the Legislature reworked the state’s criminal code in the 1970’s, it found that the wording of the felony murder statute, RCW 9A.32.050(b), no longer included assault as a predicate felony “in furtherance of” which the victim died.  It is clear from these very recent decisions, the rules of statutory construction provide that if the DSHS did not perfect service as specifically required by RCW 74.20A.320(1), it lacked jurisdiction to certify noncompliance with the support order to the DOL and the DOL lacked jurisdiction to suspend the license.

            Lack of jurisdiction is not a harmless error, all actions taken without jurisdiction are void.

            If the impact is to deny an opportunity to challenge the validity of the statutory scheme or the application of the statute in a petition for redetermination brought in this Court, including issues that could have NOT been raised in this Court in the previous civil cases (Smith and Cruz tests defined by the Supreme Court of Washington subsequent to Knight v. DSHS, King County Superior Court No. 97-2-21231-6 KNT, a clear change in the law or legal climate, see Brief of Appellant pp. 18-21), the error is not harmless, even if not void for lack of service required by the relevant statute.

            With sex offenders as considered in State v. Dahl, (1999) 139 Wash. 2d. 678, 990 P. 2d 396, the agencies or courts in hearing may consider whether the sex offender had the ability to comply with the treatment order.  If the sex offender is found unable to obtain prescribed medication, the court may enter an order that provides him with the opportunity to obtain the medication necessary for his treatment.  RCW 74.20A.320(3) specifically limits the jurisdiction of the DSHS to only three issues: whether the person named is in fact the responsible parent, whether there is a child support order, and whether the parent is in compliance with the support order.  It does not provide the DSHS with any jurisdiction to consider the ABILITY of the parent to comply with the order.  Any challenge to this statutory scheme based on this lack of opportunity to be heard as to the ability to comply is necessarily based on facts concerning the parent’s financial condition and employment opportunities AT THE TIME OF ANY SUCH ADMINISTRATIVE HEARING.  Mr. Knight’s ability to comply with the support order or lack thereof in 1997 or 1999 is irrelevant to whether he is able to comply in 2001, when the notice for such hearing was allegedly sent to him, though proof of such notice not presented in the trial court.  Therefore, as argued below, there would have been no estoppel to any challenge to RCW 74.20A.320(3) based on the 1997 civil case challenging the WorkFirst Act as a multi-subject bill.  Mr. Knight’s ability to comply with the support order or lack thereof in 1997 was irrelevant to the issue of whether the WorkFirst Act is a multi-subject bill.  Ability to comply is, however, relevant to a challenge to the WorkFirst Act as a bill of attainder, and that issue was not raised by Mr. Knight in 1997.  A parent with a pre-existing support order is arguably not legislatively punished if the legislation does not increase the amount of the support order and the parent can escape any sanction provided by the legislation by complying with the order.  If the parent is unable to comply, then the subsequent legislation imposing the sanction without consideration of ability to comply is a legislative punishment and therefore a bill of attainder.  Mr. Knight would have had to plead inability to comply to challenge the WorkFirst Act as a bill of attainder, but did not plead such inability nor did he have to plead such inability to challenge it as a multi-subject bill.  Therefore, Mr. Knight would not be estopped from challenging RCW 74.20A.320(3) on due process and bill of attainder grounds in any petition for redetermination from any such administrative proceeding if he was actually provided the service required by RCW 74.20A.320(1).

            At the least, this Court should vacate the convictions and remand with instructions that the district court must determine whether the notice requirements of RCW 74.20A.320(1) were met for the DSHS to acquire in personum jurisdiction to certify noncompliance with the support order to the DOL, and that any evidence of personal service presented be evaluated in terms of Weiss v. Glemp, (1995) 127 Wash. 2d. 726, 903 P. 2d. 455.  If personal service as required by the WorkFirst Act is found lacking, the trial court should grant, in addition to dismissal of the complaints, equitable relief requiring the DOL to restore Mr. Knight’s license without any requirement for payment of a reissue fee and to issue a new identicard, the Washington State Patrol punched a hole in Mr. Knight’s identicard.

IV.  KNIGHT V. DSHS, NO. 97-2-21231-6 KNT AND KNIGHT V. DSHS, NO. 99-2-22195-8 KNT DO NOT PRECLUDE ANY OF MR. KNIGHT’S CHALLENGES TO THE VALIDITY OF THE WORKFIRST ACT EITHER ON ITS FACE OR AS APPLIED TO MR. KNIGHT

 

            Hisle v. Todd Pacific Shipyards Corp., (September 16, 2002) _____ Wash. App. ____ revisited the issues of when res judicata should apply.  Hisle found:

            Res judicata bars all grounds for recovery that could have been asserted, whether they were or not, in a prior action between the same parties if there is a concurrence of identity in (1) the subject matter; (2) the cause of action; (3) persons and parties; and (4) the quality of the persons for or against whom the claim is made.  Deja Vu, 96 Wn. App. at 262; Karr, 994 F.2d at 1429; Rains v. State, 100 Wn.2d 660, 665, 674 P.2d 165 (1983).  If any single requirement is lacking, the doctrine does not apply, International Bhd. of Pulp, Sulphite & Paper Mill Workers v. Delaney, 73 Wn.2d 956, 960, 442 P.2d 250 (1968), and the party invoking the defense has the burden of proving its applicability.  McDaniels v. Carlson, 108 Wn.2d 299, 304, 738 P.2d 254 (1987).

 

Deja Vu is Deja Vu-Federal Way, Inc. v. City of Federal Way, (1999) 96 Wash. App. 255, 979 P. 2d. 464.  Karr is International Union of Operating Engineers v. Karr, (9th Cir. 1993) 994 F. 2d. 1426.

            Res judicata does not apply to this case because there is no identity of parties between the City of Mercer Island when prosecuting criminal charge of driving while license suspended (DWLS) and the State of Washington and its DSHS in the previous civil cases brought in this Court.  The previous civil cases arose from License Suspension Warning Letters sent by regular mail to Mr. Knight by the DSHS in September 1997 and September 1999.  Neither of these Letters provided for any administrative hearing as required by RCW 74.20A.320 for any actual suspension of the license.  No further action was taken by the DSHS with respect to suspension of Mr. Knight’s license until 2001.  There is no identity in cause of action between any civil case and any criminal case. There is not even any identity in the quality or persons against whom the claim is made.  In the civil cases, Mr. Knight was the plaintiff requesting injunction against enforcement of the WorkFirst Act as a multi-subject bill.  This present case is a criminal case where Mr. Knight is charged with driving while the license was suspended by the DSHS and the DOL pursuant to the WorkFirst Act.

            Hisle further found:

In considering whether causes of action are the same for purposes of res judicata, courts consider (1) whether rights or interests established in the prior judgment would be destroyed or impaired by prosecution of the second action; (2) whether substantially the same evidence is presented in the two actions; (3) whether the two suits involve infringement of the same right; and (4) whether the two suits arise out of the same transactional nucleus of facts.  Hayes v. City of Seattle, 131 Wn.2d 706, 713, 934 P.2d 1179, 943 P.2d 265 (1997); Constantini, 681 F.2d at 1201-02 (9th Cir. 1982).

 

Constantini is Constantini v. Trans World Airlines, (9th Cir. 1982) 681 F. 2d. 1199.  The only fact at issue in the previous civil litigation was the receipt by Mr. Knight of two letters, two years apart, threatening suspension of the licenses without any provision for the administrative hearing provided by RCW 74.20A.320.  The only issue raised by Mr. Knight at that time was whether the WorkFirst Act is void as a multi-subject bill.  To plead bill of attainder, Mr. Knight would have to plead inability to comply.  To plead violation of the Antipeonage Act, he would have to plead inability to comply without employment.  If the WorkFirst Act is a multi-subject bill, it is void regardless of any other fact, the only fact Mr. Knight had to plead was the fact sufficient to establish standing to challenge the Act: receipt of a threatening letter.  Mere fact that Mr. Knight could have pleaded the additional fact of inability to comply without employment does not mean that it is a part of the “same transactional nucleus of facts” from which the challenge to the WorkFirst Act as a multi-subject bill arose.

            In the present case, additional facts include the suspension of the license in September 2001, two years after the Letter that gave rise to Knight v. DSHS, No. 99-2-22195-8 KNT and four years after the Letter that gave rise to Knight v. DSHS, No. 97-2-21231-6 KNT, and the operation of the motor vehicle by Mr. Knight on Mercer Island on January 21, 2002 and February 2, 2002; and Mr. Knight declared under penalty of perjury that he was still several thousand dollars out of compliance with the support order when he was laid off by The Boeing Company on May 29, 1995 and has since been unable to comply with the support order: Third Declaration by Roger W. Knight in Support of Motion to Dismiss Complaint, filed in No. 84199 and the identical Declaration filed in No. 84268.  Not the same transactional nucleus of facts, not substantially the same evidence, not infringement of the same right except the claim for the right not to be governed by multi-subject bills, as was presented in the previous civil cases in this Court.

            Hisle ultimately found that a previous challenge to the validity of a collective bargaining agreement does not apply, through the doctrine of res judicata, to any challenge of the payment of the employees covered by the collective bargaining agreement as not sufficient to meet the requirement for time and a half overtime set forth by statute: RCW 49.46.130.  The right to be paid overtime wages is not to be bargained away by the employee and any such agreement is void as contrary to public policy.  The right to overtime pay is independent of any contract, and therefore, no litigation solely concerning the contract will have any res judicata effect on any subsequent litigation to enforce the statutory right to overtime compensation.

            By the same token, the right to not be targeted by a bill of attainder or held in a condition of peonage in liquidation of a debt or obligation is independent of the right to not be governed by a multi-subject bill.  A bill of attainder passed as a single subject bill is just as void, under both Article I Section 10 clause 1 of the United States Constitution and Article I Section 23 of the Washington Constitution, as when it is included as part of a multi-subject bill void as prohibited by Article II Section 19 of the Washington Constitution.  A requirement to work based upon a debt or obligation, to punished with license suspension, is declared null and void by 42 U.S.C. §1994 whether it arises from a statute, whether as part of a single subject or multi-subject bill, or a common law usage, and the federal statute includes the word “orders”.

            Res judicata simply does not apply to preclude any issue not raised in the previous civil cases because of a lack in the necessary requirements for identity of the subject matter, the parties, and the cause of action.  Therefore, the issues of the Smith and Cruz tests, and whether application of the WorkFirst Act to Mr. Knight violates the Bill of Attainder and Ex Post Facto Clauses of the Washington and United States Constitutions, and Antipeonage Act, are not precluded because these issues were not raised in the previous civil cases in this Court.  Since the original divorce case was litigated long before the WorkFirst Act was passed, no challenge to the validity of the WorkFirst Act could have been brought in that proceeding, and therefore the original divorce case in which the support order was imposed does not preclude any challenge to subsequently passed legislation.

            Which is perhaps why the City of Mercer Island pleads collateral estoppel, which applies only to the issue raised in the previous litigation, not to any other issue.  Shuman v. Dept. of Licensing, (2001) 108 Wash. App. 673 found:

A party seeking to invoke the doctrine of collateral estoppel must prove: '(1) the issue decided in the prior adjudication is identical with the one presented in the second action; (2) the prior adjudication must have ended in a final judgment on the merits; (3) the party against whom the plea is asserted was a party or in privity with the party to the prior adjudication; and (4) application of the doctrine does not work an injustice.' Thompson v. Dep't of Licensing, 138 Wn.2d 783, 790, 982 P.2d 601 (1999).

 

To apply the doctrine to preclude any challenge by Mr. Knight against the WorkFirst Act is to work an injustice.

            In Knight v. DSHS, No. 97-2-21231-6 KNT, this Court was arguably bound by In re Boot, (1996) 130 Wash. 2d. 553, 565-568, 925 P. 2d. 964 which found:

Although the Act covers a number of issues, including public health, community networks, firearms and other weapons, public safety, education, employment, and media, the title of the bill is "AN ACT Relating to violence prevention.” Laws of 1994, 1st Sp. Sess., ch. 7, at 2196.

In our recent decision in Washington Fed’n of State Employees v. State, 127 Wn.2d 544, 901 P.2d 1028 (1995), we observed the constitutional provision "is to be liberally construed in favor of the legislation.” Id. at 555. With respect to the title of the law, "this court has long recognized that a general title consisting of a few well-chosen words, suggesting the general subject stated, is all that is necessary to comply with the constitutional provision.” Id. at 554. "Where the title is general, 'any subject reasonably germane to such title may be embraced within the body of the bill.’” Id. at 555-56 (citing De Cano v. State, 7 Wn.2d 613, 627, 110 P.2d 627 (1941)).

Although this omnibus law covers a variety of subjects, they are all related to its stated purposes, which are to:

(1)  Prevent acts of violence by encouraging change in social norms and individual behaviors that have been shown to increase the risk of violence; (2) reduce the rate of at-risk children and youth, as defined in RCW 70.190.010; (3) increase the severity and certainty of punishment for youth and adults who commit violent acts; (4) reduce the severity of harm to individuals when violence occurs; (5) empower communities to focus their concerns and allow them to control the funds dedicated to empirically supported preventive efforts in their region; and (6) reduce the fiscal and social impact of violence on our society.

Laws of 1994, 1st Sp. Sess., ch. 7, § 101, at 2197-98. The title, "AN ACT Relating to violence prevention,” embraces all these purposes. "[A] title complies with the constitution if it gives notice that would lead to an inquiry into the body of the act, or indicate to an inquiring mind the scope and purpose of the law.” Young Men’s Christian Ass’n v. State, 62 Wn.2d 504, 506, 383 P.2d 497 (1963). The title of this bill meets the constitutional test.

            Cornejo and Boot also argue that because the Act covers so many wide-ranging subjects, it violates the constitutional directive forbidding bills containing more than a "single subject.” Wash. Const. art. II, § 19. We have used the 'rational unity” test to determine if a bill contains a single subject. "All that is required is that there be some 'rational unity’ between the general subject and the incidental subdivision.” Washington Fed’n, 127 Wn.2d at 556 (citing State v. Grisby, 97 Wn.2d 493, 498, 647 P.2d 6 (1982), cert. denied sub nom. Frazier v. Washington, 459 U.S. 1211, 103 S. Ct. 1205, 75 L. Ed. 2d 446 (1983)). Although we have found only nine violations of the "single subject” rule since 1891, id. at 571-72 n.6 (Talmadge, J., concurring in part/dissenting in part), articulation of the elements of rational unity has often proved elusive.

         The principal allegedly "non-germane” sections of the Act cited by Cornejo and Boot are sections other than the amendments to RCW 13.04.030(1)(e)(iv). Thus, even if Boot and Cornejo are correct about the other sections of the Act, the validity of RCW 13.04.030(1)(e)(iv) is unaffected. They do not contend RCW 13.04.030(1)(e)(iv) is itself outside the scope of the title. Moreover, a severability clause preserves the validity of the statute despite any invalidation of other sections of the Act. LAWS OF 1994, 1st Sp. Sess., ch. 7, § 913. State v. Anderson, 81 Wn.2d 234, 239-40, 501 P.2d 184 (1972).

The Legislature said in the intent section of the 1994 Act:

The legislature finds that violence is abhorrent to the aims of a free society and that it can not be tolerated. State efforts at reducing violence must include changes in criminal penalties, reducing the unlawful use of and access to firearms, increasing educational efforts to encourage nonviolent means for resolving conflicts, and allowing communities to design their prevention efforts.

The legislature finds that the problem of violence can be addressed with many of the same approaches that public health programs have used to control other problems such as infectious disease, tobacco use, and traffic fatalities.

Laws of 1994, 1st Sp. Sess., ch. 7, § 101, at 2197. The Legislature found it necessary to combine diverse provisions into a single omnibus act to address a single problem in a comprehensive way.

            In rejecting a similar challenge to an analogous omnibus bill dealing with alcohol and controlled substances (the Omnibus Alcohol and Controlled Substances Act of 1989), the Court of Appeals said:

Although the civil and criminal provisions within the act cover a broad range of activities, each of those provisions furthers the legislative purpose of counteracting drug problems which are prevalent within our society. Thus, we conclude that the act does not violate the single subject requirement of the constitution.

State v. Jenkins, 68 Wn. App. 897, 901, 847 P.2d 488, review denied, 121 Wn.2d 1032, 856 P.2d 383 (1993). See also State v. Acevedo, 78 Wn. App. 886, 887-91, 899 P.2d 31 (1995), review denied, 128 Wn.2d 1014, 911 P.2d 1343 (1996); State v. Knight, 79 Wn. App. 670, 676-77, 904 P.2d 1159 (1995), review denied, 129 Wn.2d 1005 (1996). "[I]f the legislation is an omnibus bill designed by the Legislature or the people to address a larger subject area, the wishes of the Legislature or the people in addressing an issue comprehensively in a single bill may be respected.” Washington Fed’n, 127 Wn.2d at 575-76 (Talmadge, J., concurring in part / dissenting in part).

Here, the 1994 Act is an omnibus bill, the stated purpose of which is to address a single problem, violence prevention, in a comprehensive manner. The Act meets the rational unity test of article II, section 19 of our constitution as a legitimate expression of the legislative purpose.

 

Apply this doctrine to the WorkFirst Act, or to any other omnibus bill passed by the Legislature, and Article II Section 19 becomes completely meaningless.  If the title of the bill reads: “An Act relating to Life, the Universe, and Everything, . . .” it would be single subject regardless of its contents.

            But Amalgamated Transit Union Local 587 v. State of Washington, (2000) 142 Wash. 2d. 183, 11 P. 3d. 762 reversed the essential logic of In re Boot, which upheld the Violence Reduction Act, Laws of Washington 1994 1st Sp. Sess., c. 7, as a single subject bill, and by reference affirmed three Washington Court of Appeals decisions upholding the Omnibus Alcohol and Controlled Substances Act, Laws of Washington Laws 1989 chapter 271.  Where Amalgamated Transit at 142 Wash. 2d. 217 found that Initiative 695 embraces two subject because neither subject is necessary to implement the other, it completely reverses In re Boot and State v. Jenkins, (1993) 68 Wash. App. 897, 901, 847 P. 2d. 383 as to the construction and application of Article II Section 19.  Many of the provisions of the Violence Reduction Act and the Omnibus Alcohol Act are not necessary to implement each other.  Examples: An authorization to the Department of Health to perform a study is not necessary to implement a change in a firearms statute to prohibit convicted felons from owning long firearms, and neither is necessary to implement a tax on wine, beer, cigarettes, and soft drinks in the Violence Reduction Act.  Non-criminal provisions for registration of kegs of malt liquor are not necessary to implement changes in controlled substance criminal statutes, and neither are necessary to implement drug and alcohol counseling in the public schools or to implement taxes on wine, beer, spirits, cigarettes, and carbonated beverage ingredients in the Omnibus Alcohol Act.  Subsequent to Amalgamated Transit, City of Burien v. Kiga, (2001) 144 Wash. 2d. 819, 31 P. 3d. 659 invalidated Initiative 722.  Because Amalgamated Transit and Kiga are the more recent constructions of Article II Section 19, they should control the analysis of bills challenged as multi-subject bills, including Mr. Knight’s challenge to the WorkFirst Act.

            To say that there is no change in the law or the legal climate as a result of Amalgamated Transit is like saying that there is no difference between sodium chloride (salt) and sodium cyanide.  It does violence to the rule of law and to the English language in which the law is written. It thus works an injustice to apply collateral estoppel to preclude Mr. Knight from presenting his claim that the WorkFirst Act is void as a multi-subject bill.

V.  CONCLUSION

            For the reasons stated herein, the conviction should be vacated or reversed and the case remanded for further proceedings consistent with this Court’s findings.

            Respectfully submitted this 31st day of October 2002.

 

                                                                        __________________________

                                                                        Roger W. Knight, pro se

 

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