IN THE SUPREME COURT OF THE STATE OF WASHINGTON



DANIEL MADISON, BEVERLY                             )

DUBOIS, and DANNIELLE GARNER,                       )

                                                    )

                             Respondents,           )      No. 78598-8

                                                    )

                                                    )

SEBRINA MOORE and LARENCE                           )

BOLDEN,                                             )

                                                    )

                             Plaintiffs,            )      EN BANC

                                                    )

v.                                                  )

                                                    )

STATE OF WASHINGTON; CHRISTINE                      )

O. GREGOIRE, Governor; and SAM                      )      Filed July 26, 2007

REED, Secretary of State, in their official         )

capacities,                                         )

                                                    )

                             Appellants.            )

___________________________________                 )



       FAIRHURST, J.  --  Respondents/cross-appellants Daniel Madison, Beverly 



DuBois, and Dannielle Garner (respondents) are convicted felons seeking 



reinstatement of their voting rights.  Respondents challenge the constitutionality of 



Washington's disenfranchisement scheme because it denies the right to vote to 



convicted felons who have not completed all of the terms of their sentences,  



Madison v. State, No. 78598-8



including full payment of their legal financial obligations (LFOs).1              Respondents



argue that the scheme violates the privileges and immunities clause of the 



Washington Constitution and  the equal protection clause of the fourteenth 



amendment to the United States Constitution because it denies them the right to vote 



based on wealth.  Following cross-motions for summary judgment, the trial court 



concluded that the scheme is unconstitutional as to felons who, due to their financial 



statuses, are unable to pay their LFOs immediately.  The State sought direct review 



and requests that this court reverse the trial court's order and enforce Washington's 



Constitution and statutes as written.  Respondents cross-appeal and ask this court to 



hold that all felons who have satisfied all the terms of their sentences except for full 



payment of their LFOs be allowed to vote, regardless of their financial statuses.



       We hold that Washington's disenfranchisement scheme does not violate the 



privileges and immunities clause of the Washington Constitution or  the equal 



protection clause of the United States Constitution.  We also hold that respondents 



lack standing to bring their cross-appeal, and we deny respondents' request for 



attorney fees because they are not the prevailing party. We reverse the trial court.



       1LFOs include court costs, fees, and victim restitution.  See RCW 9.94A.030(28).



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Madison v. State, No. 78598-8



                  I.     FACTUAL AND PROCEDURAL HISTORY



       The facts are undisputed.  Daniel Madison was convicted of third degree



assault in King County Superior Court in 1996.  His sentence included an order to 



pay $483.25 in restitution, $200.00 in victim assessment fees, and $100.00 in court 



costs, for a total of $783.25 in LFOs.  Madison is disabled due to mental illness, and 



his social security payments constitute his only regular monthly income.  A court 



order set his monthly payment at $15, which he regularly makes.  The court waived 



the payment of interest.  Although Madison has paid at least $530.00 toward his 



LFOs, he still owes approximately $245.25.  Madison has satisfied all of the terms 



of his sentence, with the exception of full payment of his LFOs.



       Beverly DuBois was convicted of manufacturing and delivering marijuana in 



Stevens County Superior Court in 2002.  Her sentence included an order to pay 



$1000 to the Stevens County Drug Enforcement Fund, a $500 victim assessment 



fee, and $110 in court costs, for a total of $1,610 in LFOs.  DuBois sustained a 



permanent disability from a 2000 car accident and her social security payments, 



disability payments, and food stamps constitute her only monthly income.  In 



compliance with the court's payment plan, she regularly makes $10 payments 



toward her LFOs.  Although she has paid at least $190.00, DuBois now owes 



approximately $1,895.69 due to interest accrual.  DuBois has satisfied all of the 



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Madison v. State, No. 78598-8



terms of her sentence, with the exception of full payment of her LFOs.



       Dannielle Garner was convicted of forgery in Skagit County Superior Court 



in 2003.  Her sentence included an order to pay a $500 victim assessment fee and 



$110 in court fees, for a total of $610 in LFOs.  Garner is permanently disabled due 



to mental illness, and her social security payments constitute her only monthly 



income.  Garner regularly makes $10 payments toward her LFOs in compliance with 



a court order.  The court also noted that once Garner pays the principal in full, the 



court may waive interest.  Although she has paid at least $250 toward her LFOs, she 



still owes approximately $360.  Garner has satisfied all of the terms of her sentence, 

with the exception of full payment of her LFOs.2



       Respondents filed a complaint for declaratory relief in King County Superior 



Court arguing that Washington's disenfranchisement scheme violates the equal 



protection clause of the United States Constitution and 42 U.S.C. § 1983, and the 



privileges and immunities clause and article I, section 19 of the Washington 



Constitution.  Following cross-motions for summary judgment, the trial court held 



that Washington's disenfranchisement scheme "is invalid as to all felons who have 



satisfied the terms of their sentences except for paying legal financial obligations, 



       2The original complaint named two additional plaintiffs, Sebrina Moore and Larence 

Bolden, but the parties later stipulated to the voluntary dismissal of those two plaintiffs.



                                               4 



Madison v. State, No. 78598-8



and who, due to their financial status, are unable to pay their legal financial 



obligations immediately."         Clerk's Papers (CP)        at 433.  The court granted 



respondents' summary judgment motion, denied the State's summary judgment 



motion, and ordered that Madison, DuBois, and Garner were "entitled to register to 



vote." CP at 434.



       The Commissioner granted direct review on an accelerated basis and denied 



the State's motion to stay the trial court's order pending appeal without prejudice.  



The State did not move for reconsideration or appeal the denial of the stay.



                                       II.     ISSUES



A.     Whether Washington's felon disenfranchisement scheme violates the 



       privileges and immunities clause of the Washington Constitution.



B.     Whether Washington's felon disenfranchisement scheme violates the equal 



       protection clause of the United States Constitution.



C.     On cross-appeal, whether the trial court erred by limiting its order to only 



       individuals who could not pay their LFOs immediately.



D.     Whether the respondents are entitled to attorney fees.



                                     III.    ANALYSIS



                    Challenged Provisions and  Standard of Review



       Article VI, section 3 of the Washington Constitution disqualifies from the 



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Madison v. State, No. 78598-8



franchise, or the right to vote, "[a]ll persons convicted of infamous crimes unless 



restored to their civil rights."   The Washington Legislature has defined "'infamous 



crime'" as "a crime punishable by death in the state penitentiary or imprisonment in 



a state correctional facility,"      or in other words, any felony offense.  RCW 



29A.04.079.  Once disenfranchised, felons may seek to restore their civil rights 



through a governor's pardon.  RCW 9.96.010.  Additionally, felons may also seek 



to restore their civil rights through the issuance of a certificate of discharge.  RCW 



9.94A.637.  A court may issue a certificate of discharge only when the felon has 



completed "all requirements of the sentence, including any and all legal financial 



obligations." RCW 9.94A.637(1)(a).  In order to register to vote, a felon must take 



an oath that states that he or she is "not presently denied [his or her] civil rights as a 



result of being convicted of a felony." RCW 29A.08.230.3



       The trial court held that this disenfranchisement scheme, and in particular 



RCW 9.94A.637, violates article I, section 12, and article I, section 19 of the 

Washington Constitution4        and the equal protection clause of the fourteenth 



       3Although respondents maintain that the number of currently disenfranchised felons in 

Washington State who have satisfied all of the terms of their sentences except for full payment of 

their LFOs is unknown, they note that, in 2001, the Department of Corrections estimated that 

number at 46,500.  Br. of Resp'ts/Cross-Appellants (Br. of Resp't) at 6-7.

       4Article I, section 19 of the Washington Constitution provides that "[a]ll elections shall be 

free and equal, and no power, civil or military, shall at any time interfere to prevent the free 

exercise of the right of suffrage." In their complaint, respondents listed a violation of article I, 

section 19, as a separate claim for relief.  However, the State asserts that respondents "abandoned 

that claim by failing to provide any relevant analysis of that provision." Br. of Appellants (Br. of 

Apellants) at 3 n.3.  As the State notes, respondents cited article I, section 19 in their summary 



                                               6 



Madison v. State, No. 78598-8



amendment to the United States Constitution because it discriminates on the basis of 



a felon's ability to pay his or her LFOs.  We review summary judgment motions and 



issues of constitutional interpretation de novo.  Berrocal v. Fernandez, 155 Wn.2d 



585, 590, 121 P.3d 82 (2005); In re Parentage of C.A.M.A., 154 Wn.2d 52, 57, ¶ 9, 



109 P.3d 405 (2005).  In general, "'[a] statute is presumed to be constitutional, and 



the party challenging its constitutionality bears the burden of proving its 



unconstitutionality beyond a reasonable doubt.'"  State v. Hughes, 154 Wn.2d 118, 



132, ¶ 25, 110 P.3d 192 (2005) (quoting State v. Thorne, 129 Wn.2d 736, 769-70, 



921 P.2d 514 (1996)), overruled in part on other grounds by Washington v. 



Recuenco, 126 S. Ct. 2546, 165 L. Ed. 2d 466 (2006).  Thus, the respondents bear 



the responsibility of proving that Washington's disenfranchisement scheme is 



unconstitutional beyond a reasonable doubt.  When presented with arguments under 



both the Washington and federal constitutions, we review the state constitutional 



arguments first.  State v. Reece, 110 Wn.2d 766, 770, 757 P.2d 947 (1988).



judgment motion only in relation to their privileges and immunities claim, not as an independent 

basis for decision.  In this court, respondents again cite article I, section 19 only in relation to their 

privileges and immunities argument.  

       Although the trial court cited article I, section 19 in its ruling, we decline to review that 

provision as an independent basis for invalidating Washington's disenfranchisement scheme.  See

CP at 446.  Respondents have failed to argue in this court or in the court below how they are 

entitled to relief under article I, section 19.  This court does not consider assignments of error 

unsupported by argument.  Cowiche Canyon Conservancy v. Bosley, 118 Wn.2d 801, 809, 828 

P.2d 549 (1992).  Thus, we do not consider article I, section 19 as a basis for invalidating 

Washington's disenfranchisement scheme separate from respondents' privileges and immunities 

clause arguments.



                                               7 



Madison v. State, No. 78598-8



A.     Washington's felon disenfranchisement scheme does not violate the privileges 

       and immunities clause of the Washington Constitution



       The State argues that respondents do not assert a valid claim under the 



privileges and immunities clause of the Washington Constitution.  Article I, section 



12 provides that "[n]o law shall be passed granting to any citizen, class of citizens, 



or corporation other than municipal, privileges or immunities which upon the same 



terms shall not equally belong to all citizens, or corporations."         Respondents argue 



that this court must  "conduct a separate and independent inquiry into the 



constitutionality of [Washington's disenfranchisement scheme] under Washington's 



Constitution." Br. of Resp'ts/Cross-Appellants (Br. of Resp'ts) at 32.  To that end, 



respondents engage in an analysis of the factors laid out in State v. Gunwall, 106 



Wn.2d 54, 720 P.2d 808 (1986), to determine whether the privileges and immunities 



clause of the Washington Constitution is more protective of the right to vote than is 



the equal protection clause of the United States Constitution.  



       This court engages in a two step inquiry when considering a claim that a 



provision of the Washington Constitution provides additional protection than is 



provided under a provision of the United States Constitution.5  First, we determine 



       5It is well settled that a party raising a claim under a state constitutional provision must 

brief the  Gunwall factors to the extent required by this court's jurisprudence.  Where our 

precedent establishes that a separate and independent analysis of a state constitutional provision is 

warranted, further Gunwall analysis is unnecessary to establish that point.  However, parties may 

consider and brief the Gunwall factors as interpretive devices in support of our constitutional 

interpretation inquiry.   See Hugh D. Spitzer,  New Life for the  "Criteria Tests" in State 



                                               8 



Madison v. State, No. 78598-8



whether  "a provision of the state constitution should be given an interpretation 



independent from that given to the corresponding federal constitutional provision."  



State v. McKinney, 148 Wn.2d 20, 26,  60 P.3d 46 (2002).                   This  first  analysis 



considers the six nonexclusive, neutral Gunwall factors:  (1) the textual language of 



the state constitution, (2) differences in the texts of parallel provisions of the federal 



and state constitutions, (3) state constitutional and common law history, (4) 



preexisting state law, (5) structural differences between the federal and state 



constitutions, and (6) matters of particular state or local concern.  Gunwall, 106 



Wn.2d at 58.  



       If we determine that an independent analysis is warranted, we then analyze



"whether the provision in question extends greater protections for the citizens of this 



state."  McKinney, 148 Wn.2d at 26.  This second analysis focuses on whether our 



state constitution provision is more protective of the claimed right in the particular 



context than is the federal constitution provision, and the scope of that protection.  



Such an "analysis involves, among other things, an examination of the language of 



the provision, its relationship to other constitutional provisions, the existing and 



preceding statutory and common law at the time it was adopted, and other historical 



context."    Concurrence (Madsen, J.) at 3.   The  six  Gunwall factors parallel 



Constitutional Jurisprudence:  "Gunwall is Dead--Long Live Gunwall!", 37 Rutgers L.J. (2006).



                                               9 



Madison v. State, No. 78598-8



interpretive inquiries    made when       determining  "whether the state          constitution 



ultimately provides greater protection than its corresponding federal provision."  Ino 



Ino, Inc. v. City of Bellevue, 132 Wn.2d 103, 115, 937 P.2d 154, 943 P.2d 1358



(1997) (citing State v. Boland, 115 Wn.2d 571, 575, 800 P.2d 1112 (1990)).



       This court previously determined that the privileges and immunities clause of 



the Washington Constitution "requires an independent constitutional analysis from 



the equal protection clause of the United States Constitution."6  Grant County Fire 



Prot. Dist. No. 5 v. City of Moses Lake, 150 Wn.2d 791, 811, 83 P.3d 419 (2004) 



(Grant County  II).   Once  this court has  established that a state constitutional 



provision warrants an analysis independent of a particular federal provision, it is 



unnecessary to engage repeatedly in further Gunwall analysis simply to rejustify 



performing that separate and independent constitutional analysis.  State v. White, 



135 Wn.2d 761, 769, 958 P.2d 982 (1998).  Thus, Grant County II's determination



       6Justice Madsen asserts that "an independent analysis applies under article I, section 12 

only where the challenged legislation grants a privilege or immunity to a minority class, that is, in 

the case of a grant of positive favoritism."  Concurrence (Madsen, J.) at 1 (emphasis added).  

However, Grant County II did not impose this limitation on its determination that article I, section 

12 warrants an independent analysis from the equal protection clause of the United States 

Constitution.   See Grant County II, 150 Wn.2d at 805 ("[W]e hold that the privileges and 

immunities clause of the Washington State Constitution, article I, section 12, requires an 

independent constitutional analysis from the equal protection clause of the United States 

Constitution.");  id. at 806 ("In determining that  our state constitutional provision requires a 

separate and independent constitutional analysis from the United States Constitution, we consider 

[the Gunwall] criteria."); id. at 811 ("For the reasons dictated by the preceding Gunwall analysis, 

we hold that article I, section 12 of the Washington State Constitution requires an independent 

constitutional analysis from the equal protection clause of the United States Constitution.").



                                              10 



Madison v. State, No. 78598-8



satisfies the first step of our inquiry.  



       In considering the respondents' privileges and immunities claim  we must 



initially address whether the right to vote is a privilege or immunity that is protected 



by article I, section 12 of the Washington Constitution.  "For a violation of article I, 



section 12 to occur, the law, or its application, must confer a privilege to a class of 



citizens."  Grant County II, 150 Wn.2d at 812.  Although the precise confines of 



what constitutes a privilege remains unclear, this court has stated that for the 



purposes of article I, section 12, privileges are "'those fundamental rights which 



belong to the citizens of the state by reason of [their state] citizenship.'"  Id. at 813 



(quoting State v. Vance, 29 Wash. 435, 458, 70 P. 34 (1902)).  This court has 



previously recognized that the right to vote is a fundamental right afforded to the 



citizens of Washington  State.7       See, e.g., Foster v. Sunnyside Valley Irrigation 



Dist., 102 Wn.2d 395, 404, 687 P.2d 841 (1984).                Article I, section 19 of the 



Washington Constitution prohibits interference with "the free exercise of the right of 



suffrage."   Therefore, we conclude that the right to vote is a privilege of state 



       7Justice J.M. Johnson's concurrence would have this court limit the right to vote, for 

purposes of the privileges and immunities clause, to "'the elective franchise, as regulated and 

established by the laws or constitution of the state.'"   Concurrence (J.M. Johnson, J.) at 4 

(quoting Corfield v. Coryell, 4 Wash. C.C. 371, 6 F. Cas. 546, 552 (C.C.E.D. Pa. 1823) (No. 

3,230).  Justice J.M. Johnson's approach would seem to insulate statutory voting restrictions from 

any review under the privileges and immunities clause because every such restriction would, by 

definition, be encompassed within the "elective franchise as regulated."  We reject this narrow 

construction of the fundamental right to vote.



                                              11 



Madison v. State, No. 78598-8



citizenship, implicating the privileges and immunities clause of the Washington 



Constitution.



       Having  determined that  the privileges and immunities clause warrants  an 



independent state constitutional analysis and that the right to vote is a privilege 



implicating the clause, we now focus on the second step of our inquiry: whether and 



to what extent the clause provides greater protection in the context of felon voting.  



As previously     mentioned,  the  Gunwall        factors   parallel inquiries made when 



interpreting a state constitutional provision to determine the extent of the protection 



it provides in a particular context.  Boland, 115 Wn.2d at 575.  Here an analysis of 



preexisting state law (Gunwall factor four) is especially useful. 



       With respect to preexisting state law, respondents argue that article I, section 



19, which confers the right to  "free and equal"              elections, indicates that the 



Washington Constitution provides greater protection of the right to vote under the 



privileges and immunities clause than does the federal constitution.  Respondents 



also cite the provisions of article VI, sections 4-7, which provide for residency 



contingencies, prevent arrest during attendance at elections, and require secret 



ballots and voter registration laws, as proof of the requirement of "affirmative state 



action to protect the right to vote against state interference."  Br. of Resp'ts at 37.



This court has recognized that the Washington Constitution goes further to 



                                              12 



Madison v. State, No. 78598-8



safeguard the right to vote than does the federal constitution.  See, e.g., Foster, 102 



Wn.2d at 404 ("Because we find that the Washington Constitution goes further to 



safeguard this right than does the federal constitution, we base our decision here 



upon the Washington Constitution.").  



       However, this court has recognized that increased protection only in relation 



to individuals who currently possess the fundamental right to vote, not felons whose 



voting rights have been stripped.  While article I, section 19 explicitly grants the 



right to "free and equal" elections, article VI, section 3 explicitly mandates the 



disenfranchisement of felons.   Reading  the mandate to disenfranchise felons in 



article VI, section 3 in conjunction with article I, section 12, we conclude that 



article I, section 12 of the Washington Constitution does not provide greater 



protection of voting rights for felons than does the equal protection clause of the 



federal constitution.



       Finally, the  respondents fail to  assert a privileges and immunities clause 



violation because Washington's disenfranchisement scheme does not involve a grant 



of favoritism.   In  Grant County  II, we explained that the text of the federal 



constitution  "is concerned with majoritarian threats of invidious discrimination 



against nonmajorities," while the state constitution "protects as well against laws 



serving the interest of special classes of citizens to the detriment of the interests of 



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Madison v. State, No. 78598-8



all citizens."   150 Wn.2d at 806-07.  Respondents argue that Washington's 



disenfranchisement scheme confers the privilege of vote restoration only on a 



minority of felons with financial resources and that Washington's privileges and 



immunities clause protects against such favoritism toward the wealthy.



       The privileges and immunities clause  does  reflect, in part, our framers'



concerns    with    "undue political influence exercised by those with large 



concentrations of wealth" and  "avoiding favoritism toward the wealthy." Grant 



County II, 150 Wn.2d at  808.   However,  such concerns are not  triggered by 



Washington's felon disenfranchisement scheme because it grants the "privilege" of 



restoration of voting rights "upon the same terms . . . equally . . . to all citizens."  



Const. art. I, § 12.  The Washington Constitution grants the right to vote to all 



Washington citizens  on equal terms.  Additionally, the Washington Constitution 



disqualifies voters on equal terms--that is, when individuals have been convicted of 



committing a felony.  Finally, Washington's statutory disenfranchisement scheme 



provides for the restoration of voting rights to felons on equal terms--that is, only 



after individuals have satisfied all of the terms of their sentences.  If those terms 



include payment of LFOs, then the full payment of LFOs is one of the prerequisites 



to restoration of voting rights.  The system of only restoring voting rights to felons 



who have satisfied all of the terms of their sentences, including fully paying their 



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Madison v. State, No. 78598-8



LFOs, does not constitute a grant of favoritism or a granting of a privilege on 



unequal terms, in violation of article I, section 12, because the same standard is 



applied evenly to all felons seeking restoration of their voting rights.  



       Therefore, we hold that the Washington Constitution is not more protective of



the right to vote in this context, and that the respondents have failed to assert an 



article I, section 12 violation.    The restoration of voting rights to felons who have 



fully paid their LFOs does not constitute a grant of favoritism in violation of the 



privileges and immunities clause of the Washington Constitution.  Thus, we consider 



respondents'    claims under the equal protection clause of the United States 



Constitution.



B.     Washington's felon disenfranchisement scheme  does not violate the equal 

       protection clause of the United States Constitution



       The trial court held that Washington's disenfranchisement scheme violated 



the equal protection clause of the fourteenth amendment to the United States 



Constitution and the privileges and immunities clause of the Washington 



Constitution because it unconstitutionally discriminates on the basis of wealth.  The 



court concluded that the State failed to prove "a rational relationship between a 



felon's ability to immediately pay LFOs and a denial of the right to vote."               CP at 



445.  In this court, respondents renew their argument that Washington's felon 



disenfranchisement scheme is subject to strict scrutiny because it denies individuals 



the fundamental right to vote.  Thus, we

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Madison v. State, No. 78598-8



must first consider whether felons possess a constitutionally protected right to vote, 



the denial of which is subject to strict scrutiny.



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Madison v. State, No. 78598-8



       1.     Felons do not possess a constitutionally protected right to vote



       As the trial court noted, "[r]emarkably little is said in the Federal Constitution 



regarding the right to vote" and "[i]t is mentioned almost in passing in Article I, 



Sections 2 and 4."      CP at 438.  However, the United States Supreme Court has 



repeatedly recognized that the right to vote is fundamental for all citizens.  See, e.g., 



Reynolds v. Sims, 377 U.S. 533, 561-62, 84 S. Ct. 1362, 12 L. Ed. 2d 506 (1964).  



Moreover, article I, section 19 of the Washington Constitution declares that "no 



power, civil or military, shall at any time interfere to prevent the free exercise of the 



right of suffrage."      Thus, because the right to vote  has been recognized as



fundamental for all citizens, restrictions on that right generally are subject to strict 



scrutiny, meaning they must be narrowly tailored to further a compelling state 



interest.  Id. at 562; City of Seattle v. State, 103 Wn.2d 663, 670, 694 P.2d 641 



(1985). 



       However, the State disputes that felons have a constitutionally protected right 



to vote.  Although respondents' equal protection claim is based on section 1 of the 

fourteenth amendment to the United States Constitution,8 section 2 of the Fourteenth 



Amendment provides that "when the right to vote at any election . . . is denied to 



       8"No state shall make or enforce any law which shall abridge the privileges or immunities 

of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, 

without due process of law; nor deny to any person within its jurisdiction the equal protection of 

the laws."  U.S. Const. amend. XIV, § 1.



                                              17 



Madison v. State, No. 78598-8



any of the male inhabitants of such state . . . or in any way abridges, except for 



participation in rebellion, or other crime, the basis of representation therein shall 



be reduced."    (Emphasis added.)      The State asserts that section 2 of the Fourteenth 



Amendment explicitly condones the disenfranchisement of criminals and, as a result,



that  any restriction on felons'       right to vote  does      not violate the Fourteenth 



Amendment.



       The State  asserts that the United States             Supreme Court reached the 



conclusion that felons do not possess a constitutionally protected right to vote in



Richardson v. Ramirez, 418 U.S. 24, 94 S. Ct. 2655, 41 L. Ed. 2d 551 (1974), 



based on section 2 of the Fourteenth Amendment.  In  Richardson, three felons 



challenged the constitutionality of California's felon disenfranchisement scheme, 



which provided that felons' voting rights could be restored "by court order after the 



completion of probation, or, if a prison term was served, by executive pardon after 



completion of rehabilitation proceedings."  Id. at 30 (footnote omitted).  In response 



to the felons' arguments that the State must show a "compelling state interest" to 



justify denial of the right to vote to felons, the Court cited the provisions of section 2



of the Fourteenth Amendment.  



       We hold that the understanding of those who adopted the Fourteenth 

       Amendment, as reflected in the express language of § 2 and in the 

       historical and judicial interpretation of the Amendment's applicability 

       to state laws disenfranchising felons, is of controlling significance in 

       distinguishing such laws from those other state limitations on the 



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Madison v. State, No. 78598-8



       franchise which have been held invalid under the Equal Protection 

       Clause by this Court. . . . [W]e may rest on the demonstrably sound 

       proposition that § 1, in dealing with voting rights as it does, could not 

       have been meant to bar outright a form of disenfranchisement which 

       was expressly exempted from the less drastic sanction of reduced 

       representation which          §    2 imposed for other               forms of 

       disenfranchisement.



Id. at 54-55.  Thus, the Court rejected the felons' argument that the State must



demonstrate a compelling interest in order to disenfranchise felons and held that 



felons' right to vote is not constitutionally protected.



       Amicus curiae League of Women Voters of Washington asserts that 



Richardson  does not stand for the proposition that the right to vote is not 



fundamental for felons.  However, Richardson clearly distinguished the right that is 



at stake for felons from the Court's previous  holdings that  citizens possess a 



fundamental right to vote.  "As we have seen, however, the exclusion of felons from 



the vote has an affirmative sanction in § 2 of the Fourteenth Amendment, a sanction 



which was not present in the case of the other restrictions on the franchise which 



were invalidated in the cases on which respondents rely."  Richardson, 418 U.S. at 



54.  



       Furthermore, other courts have read  Richardson  as holding that felon 



disenfranchisement schemes are not subject to strict scrutiny because felons' right to 



vote is not constitutionally protected.  For example, in Williams v. Taylor, 677 F.2d 



                                              19 



Madison v. State, No. 78598-8



510, 514 (5th  Cir. 1982),  which challenged             Mississippi's disenfranchisement 



scheme as violating a felon's due process rights, the United States Court of Appeals 



for the Fifth Circuit noted that a felon's "interest in retaining his right to vote is 



constitutionally distinguishable from the 'right to vote' claims of individuals who are 



not felons."   As a result, the Williams court concluded that the disenfranchisement 



statute need withstand only rational basis review and noted that the Supreme Court 



had upheld a "fundamentally identical" system in Richardson.  Id.  Similarly, in 



Owens v. Barnes,  711 F.2d 25, 27 (3d Cir. 1983),  the United States Court of 



Appeals for the Third Circuit concluded that "[i]t follows [from Richardson] that the 



standard of equal protection scrutiny to be applied when the state makes 



classifications relating to disenfranchisement of felons is the traditional rational 



basis standard."    Thus, we conclude that Richardson dictates that we hold that the 

right to vote is not fundamental for convicted felons.9  



       Without reconciling  Richardson, the dissent insists that voting remains a 



fundamental right  of which  felons cannot be deprived for failure to pay their 



       9Respondents repeatedly refer to themselves as "ex-felons."  See, e.g., Br. of Resp'ts at 2 

("Plaintiffs Daniel Madison, Beverly DuBois, and Dannielle Garner are  ex-felons who have 

completed all terms of their sentences, with the exception of the full payment of [LFOs.]"

(emphasis added)).  The term "ex-felon" is inaccurate.  Once convicted, an individual who has 

committed a felony remains a "felon," even after the individual receives a certificate of discharge.  

See RCW 9.94A.637(2) ("The department shall create and maintain a data base containing the 

names of all felons who have been issued certificates of discharge, the date of discharge, and the 

date of conviction and offense." (emphasis added)).



                                              20 



Madison v. State, No. 78598-8



financial obligations.  Dissent at 4.  However, the dissent's reasoning is unsound



because it relies on an  overstatement of  the  precedent governing the  right of 



freedom and  indigent felons' imposed financial obligations and  an unpersuasive 



analogy between the rights of freedom and voting.  



       The dissent  cites     Williams v. Illinois     and  Bearden v. Georgia          for  the 



proposition that "once all of the assigned punishment has been imposed, except for 



the payment of financial obligations, failure to pay those financial obligations cannot 



be used to continue depriving felons of their freedom." Dissent at 4 (citing Williams 



v. Illinois, 399 U.S. 235, 90 S. Ct. 2018, 26 L. Ed. 2d 586 (1970); Bearden v. 



Georgia, 461 U.S. 660, 103 S. Ct. 2064, 76 L. Ed. 2d 221 (1983)).  However, 



contrary to the dissent's assertion, Williams and Bearden do not stand for such a 



broad principle.  The Williams court held "only that a State may not constitutionally 



imprison  beyond the maximum duration fixed by statute a defendant who is 



financially unable to pay a fine."     399 U.S. at 243 (emphasis added).  The Bearden



court merely held it unconstitutional to revoke automatically an indigent defendant's 



probation for failure to pay a fine, without evaluating whether the defendant had 



made bona fide efforts or what alternative punishments might exist.  461 U.S. at 672-



73.  Neither case supports the dissent's blanket assertion that  "failure to 



pay . . . financial obligations cannot be used to continue depriving felons of their 



                                              21 



Madison v. State, No. 78598-8



freedom." Dissent at 4.  



       The dissent relies on its overstatement of Williams and Bearden to reason as 



follows:  (1) freedom is a fundamental right that can be taken away as punishment 



for a felony, (2) felons cannot continue to be deprived of their freedom for failure to 



pay a fine, (3) therefore freedom remains a fundamental right.  Dissent at 4.  The 



dissent then claims that what is true of freedom is likewise true of voting because 



voting is also a fundamental right that can be taken away as punishment for a felony.  



Id.  



       The analogy the dissent draws between the two rights is flawed.  We agree 



that both the right to vote and the right to be free from incarceration are protected by 



the equal protection clause of section 1 of the Fourteenth Amendment.  However, 



the dissent fails to grapple with the impact of section  2                 of the  Fourteenth 



Amendment upon the right to vote  for felons.   Section  2 contains no parallel 



language restricting felons' right to be free from incarceration.  Thus the dissent's 



analogy is of limited value.  The dissent's conclusion that, like freedom from 



incarceration, voting "remains a fundamental right, and when all other conditions of 



a sentence have been fulfilled, felons cannot be deprived further of their right to vote 



for failure to pay LFOs," is unsupported.  Id.  



       2.    Washington's disenfranchisement scheme is rationally related to 

             legitimate state interests



       Because no fundamental right is at 

                                              22 



Madison v. State, No. 78598-8



stake in this case and respondents do not allege that they constitute a suspect class, 



we do not apply strict scrutiny in analyzing Washington's disenfranchisement 



scheme.  We next consider whether to apply intermediate scrutiny or rational basis 



review.  Intermediate scrutiny is not appropriate in this case because this court has 



held that "intermediate scrutiny will be applied only if the statute implicates both an 



important right and a semi-suspect class not accountable for its status."  In re Pers. 



Restraint of Runyan, 121 Wn.2d 432, 448, 853 P.2d 424 (1993).  Respondents have 



failed to establish that felons' right to vote qualifies as an important right under 



federal case law.       Additionally, even though low-income felons may not be 



accountable for their wealth status, they have been adjudicated responsible for their 



status as felons, which is the classification at issue.  Therefore, we do not apply



intermediate scrutiny, and we examine Washington's disenfranchisement scheme 



using rational basis review.  Under rational basis review, this court must uphold a 



law establishing classifications unless the "'classification rests on grounds wholly 



irrelevant to the achievement of legitimate state objectives.'"   Habitat Watch v. 



Skagit County, 155 Wn.2d 397, 414, 120 P.3d 56 (2005) (quoting State v. Harner, 



153 Wn.2d 228, 235-36, 103 P.2d 738 (2004)).



       In considering respondents' equal protection claim, we must determine what 



classification Washington's disenfranchisement scheme establishes.  The State 



                                              23 



Madison v. State, No. 78598-8



asserts that the scheme does not establish a wealth-based classification because 



"[t]he only classification drawn by Washington law is between those who have 



completed all of the terms of their sentences and those who have not."                   Br. of 



Appellants at 19.  Although it is clear that the requirement that felons pay their 



LFOs in full may impact felons disparately based on their differing income statuses, 



this alone does not establish an equal protection violation.  "'[T]he equal protection 



clause does not require a state to eliminate all inequalities between the rich and the 



poor.'"  Runyan, 121 Wn.2d at 449 (quoting Riggins v. Rhay, 75 Wn.2d 271, 283, 



450 P.2d 806 (1969)).  



       In Runyan, prisoners challenged the constitutionality of a time-bar statute, 



arguing that the statute violated "the equal protection rights of indigent prisoners 



because they are unable to acquire legal representation quickly enough to 



collaterally attack their convictions."      121 Wn.2d at 448.  We upheld the statute 



because it made "no distinction among rich or poor prisoners and applie[d] equally 



to both."   Id. at 449.  Similarly, in this case, Washington's  disenfranchisement 



scheme does not distinguish between rich or poor felons but instead requires all 



felons to complete all of the terms of their sentences before they may seek 



reinstatement of their civil rights.   Thus, we conclude that  Washington's



disenfranchisement scheme does not classify based on wealth.10



                                              24 



Madison v. State, No. 78598-8



       Respondents assert that even if Washington's  disenfranchisement scheme 



may appear facially neutral, the scheme discriminates in operation.  Respondents 



cite Williams, 399 U.S. at 242 (quoting Griffin v. Illinois, 351 U.S. 12, 17 n.11, 76 



S. Ct. 585, 100 L. Ed. 891 (1956)),  in which the Court noted that  "'a law 



nondiscriminatory on its face may be grossly discriminatory in its operation.'"  In 



Williams, the Court held that an Illinois statute that allowed for the continued 



incarceration of prisoners beyond the statutory maximum sentence because the 



prisoners had failed to pay their fines violated the equal protection rights of those 



indigent prisoners.  399 U.S. at 241.  However, as the State notes, Williams is 



distinguishable from this case because it involved an individual's fundamental right 



to be free from involuntary confinement, whereas this case concerns the right of 



felons to vote, which is not constitutionally protected.  



       In another case cited by respondents, Bearden, 461 U.S. at 672-73, the Court 



held that the  state  violated the fundamental fairness required by the Fourteenth 



       10Amici curiae Brennan Center for Justice at New York University School of Law et al. 

(BCJ) argue that Washington's felon disenfranchisement scheme was motivated by racism and 

disproportionately burdens racial minorities.  Br. of Amici Curiae BCJ at 9-17.  As the State 

notes, respondents have never argued that Washington's disenfranchisement classifies on the basis 

of race.  Appellants/Cross Resp'ts Reply Br. to Brs. of Amici Curiae at 14.  This court does not 

consider issues raised first and only by amici.  Citizens for Responsible Wildlife Mgmt. v. State, 

149 Wn.2d 622, 631, 71 P.3d 644 (2003) (citing Sundquist Homes, Inc. v. Snohomish County 

Pub. Util. Dist. No. 1, 140 Wn.2d 403, 413, 997 P.2d 915 (2000)).  Thus, we will not consider 

whether the statutes at issue here discriminate on the basis of race.



                                              25 



Madison v. State, No. 78598-8



Amendment by revoking probation for failure to pay fines without inquiring into the 



reasons for the failure to pay.  Bearden, like Williams, also involves a deprivation of 



"conditional freedom" and has the effect of turning "a fine into a prison sentence."  



Id. at 672, 674.  Additionally, both  Williams  and  Bearden involve  additional 



punishments imposed on individuals for failure to pay their fines.  Here, no 



additional punishment is imposed--all felons simply cannot seek restoration of their 



civil rights until they have completed all of the terms of their sentences.



       Respondents also argue that the requirement that felons complete all the terms 



of their sentences, including full payment of their LFOs, constitutes an 



unconstitutional poll tax.  Respondents rely largely on  Harper v. Virginia  State 



Board of Elections, 383 U.S. 663, 670, 86 S. Ct. 1079, 16 L. Ed. 2d 169 (1966), in 



which the United States Supreme Court invalidated a Virginia poll tax because it 



violated the equal protection clause.  However, the poll tax in Harper applied to all 



Virginia citizens, individuals who possessed a fundamental right to vote under the 



United States Constitution.  Convicted felons, on the other hand, no longer possess 



that fundamental right as a direct result of their decisions to commit  a felony.  



Additionally, while Harper holds that wealth is "not germane to one's ability to 



participate intelligently in the electoral process," that is not the inquiry in this case.  



Id. at 668.  The correct inquiry is whether a felon's completion of the terms of his or 



                                              26 



Madison v. State, No. 78598-8



her sentence is germane to one's participation in the electoral process.  Thus, 



Harper is distinguishable on the basis that it involved a fundamental right, whereas 



this case does not.  As a result, we need consider only whether there is a rational 



relationship between requiring felons to satisfy all of the terms of their sentences, 



including full payment of their LFOs, and any legitimate governmental interests,



                                              27 



Madison v. State, No. 78598-8



such as punishment, before a felon may receive reinstatement of his or her voting 

rights.11  



       The parties also dispute how the issue in this case should be framed and 



whether the correct inquiry is if Washington's  disenfranchisement                  scheme is 



constitutional or if Washington's scheme to  restore voting rights to felons is 



constitutional.  The respondents argue that although the State has the right to 



disenfranchise felons, it may not condition the restoration of their voting rights on 

the payment of LFOs.12       The State, on the other hand, argues that the respondents 



reframing of the issue creates a "fiction" because "[t]he so-called conditions for 



reinstatement that Respondents claim to challenge are nothing more than a 



description of the period of disenfranchisement -- a description of its duration." Br. of 



Appellants at 10.  As the State argues, the provisions in the state and federal 



constitutions allowing for disenfranchisement of felons do not state a time limit.  In 



fact, a state may permanently disenfranchise a felon without violating his or her 



constitutional rights.  



       11 Confusingly the dissent seems to rely on Shepherd v. Trevino, 575 F.2d 1110, 1114 (5th 

Cir. 1978), to support the contention that Harper does apply to felons' right to vote.  Dissent at 

5.  However, the dissent's quote from the Shepherd court simply asserts, as we do here, that 

rational basis is the appropriate standard of review for such classifications.  Id.

       12The dissent agrees with respondents that this case is "about felon re-enfranchisement,"

not "felon disenfranchisement." Dissent at 3.  However, the dissent does not expand upon why it 

finds reframing the issue to be dispositive.



                                              28 



Madison v. State, No. 78598-8



       Moreover, it is not Washington's  re-enfranchisement  statute that denies 



felons the right to vote but rather the continuing applicability of its 



disenfranchisement scheme.  The United States Court of Appeals for the Ninth 



Circuit noted in Farrakhan v. Washington, 338 F.3d 1009, 1022 (9th Cir. 2003), 



when considering the constitutionality of Washington's felon disenfranchisement 



scheme under section 2 of the Voting Rights Act Amendments of 1982, 42 U.S.C. §



1973, that the felon plaintiffs in that case had "not been denied the right to vote 



because   of the restoration process, but         rather due to the disenfranchisement 



provision . . . and because they ha[d] not satisfied all the requirements of their 



sentences to become statutorily eligible for discharge of their convictions."  



Additionally, we conclude that the requirement that felons pay their LFOs should



not be divorced from the context in which that requirement arose, which was as a 



result of the individual's commission of a felony.        Thus, the requirement that felons 



must pay their LFOs is not merely a condition for reinstatement of voting rights, it is 



a requirement that felons must satisfy to complete the terms of their sentences.



       Even if the correct inquiry in this case were whether Washington's re-



enfranchisement scheme passes constitutional muster, we would hold that it does.  



Richardson involved three individual felons who had completed their sentences and 



paroles.  418 U.S. at 26.  The Court noted that when it had previously considered 



                                              29 



Madison v. State, No. 78598-8



exclusions of "some or all" felons from the franchise, it had "indicated approval of 



such exclusions on a number of occasions."  Id. at 53.  Additionally, as the United 



States Court of Appeals for the Fifth Circuit observed about the  Richardson 



decision, "although the analysis engaged in by the Court focuses on a state's power 



to disenfranchise persons convicted of a felony generally, the specific holding of the 



Court was that a state may deny the franchise to that group of 'convicted felons who 



have completed their sentences and paroles.'"  Shepherd v. Trevino, 575 F.2d 1110, 



1114 (5th Cir. 1978) (quoting Richardson, 418 U.S. at 56). The Shepherd court, in 



upholding the constitutionality of a Texas re-enfranchisement scheme, concluded 



that "the [Richardson] Court clearly envisioned that a state could grant the right to 



vote to some persons convicted of a felony while denying it to others."  Id. at 1114.  



Thus, we conclude that Washington's re-enfranchisement statute is constitutional so



long as the classification drawn is rationally related to a legitimate state interest.



       Respondents also argue that the State's asserted interests in requiring felons 



to pay their LFOs before having their voting rights restored are not legitimate state 



interests that provide a rational basis for Washington's disenfranchisement scheme.  



Respondents challenge the State's asserted interests in limiting political 



participation of those unwilling to abide by laws and in requiring the completion of 



all sentence elements before the right to vote is restored.13 Respondents argue that a 



                                              30 



Madison v. State, No. 78598-8



felon's ability to pay his or her LFOs immediately does not indicate whether he or 



she is law-abiding.  Additionally, respondents argue that the State may not "justify 



otherwise unconstitutional laws simply by asserting its interest in having its laws 



followed" and that such an argument is circular.  Br. of Resp'ts at 21.  



       However, in Green v. Board of Elections, 380 F.2d 445, 451 (9th Cir. 1967), 



the United States Court of Appeals for the Ninth Circuit recognized the legitimate 



interest in denying the right to vote to those who have committed felonies.  "[I]t can 



scarcely be deemed unreasonable for a state to decide that perpetrators of serious 



crimes shall not take part in electing the legislators who make the laws, the 



executives who enforce these, the prosecutors who must try them for further 



violations, or the judges who are to consider their cases."   Id.  Respondents'



argument that the State's asserted interest in having its laws followed is circular is 



not persuasive.  The State clearly has an interest in ensuring that felons complete all 



of the terms of their sentence, and there is no requirement that the State restore 



voting rights to felons until they do so.  



       As a result, respondents fail to establish that the requirement that felons 



complete all of the terms of their sentence, including full payment of any LFOs, is 



       13As respondents note, the State appears to have abandoned on appeal its third stated 

interest in the "important public functions" served by LFOs.  Br. of Resp'ts at 16.



                                              31 



Madison v. State, No. 78598-8



"wholly irrelevant" to any "legitimate state objective."  Therefore, we hold that 



Washington's disenfranchisement scheme does not violate the equal protection 



clause of the fourteenth amendment to the United States Constitution because it is 



rationally related to legitimate state interests. We reverse the trial court and uphold 



Washington's statutes and constitution as written. 14



C.     The respondents lack standing to bring their cross-appeal



       On cross-appeal, respondents challenge the limitation of the trial court's order 



invalidating Washington's disenfranchisement scheme only for "felons who have 



satisfied the terms of their sentences except for paying legal financial obligations, 



and who, due to their financial status, are unable to pay their legal financial 



obligations immediately."      CP at 433.  Respondents assert that all felons who have 



satisfied the terms of their sentences, except for full payment of their LFOs, should 



be allowed to vote, regardless of their financial statuses.  We note initially that



respondents likely lack standing to bring this cross-appeal because they are not an 



       14Many of the respondents'        arguments in opposition to Washington's felon 

disenfranchisement scheme relate to the process of seeking re-enfranchisement and the burden the 

requirement to pay LFOs places on low-income felons.  These arguments are not pertinent to an 

equal protection claim.  While we uphold the disenfranchisement scheme, we emphasize that we 

are not making a judgment about whether the requirement that felons complete payment of their 

LFOs before receiving restoration of their civil rights makes sense from a policy perspective.  

When the Supreme Court considered the argument in Richardson that denying felons the right to 

vote was "outmoded" and did not aid in rehabilitating felons, the court noted that it "would by no 

means discount these arguments if addressed to the legislative forum which may properly weigh 

and balance them against those advanced in support of California's present constitutional 

provisions.  But it is not for us to choose one set of values over the other." 418 U.S. at 55.



                                              32 



Madison v. State, No. 78598-8



aggrieved party under RAP 3.1, which states that "[o]nly an aggrieved party may 



seek review by the appellate court."         All of the respondents were covered by the 



trial court's order holding that the respondents were entitled to register to vote.  



Thus, the respondents were prevailing parties, not aggrieved parties.



       Respondents also argue that, as the United States argued in its amicus brief in 



Harper, merely prohibiting a poll tax in relation to indigents would create an 



ongoing hardship because "'it would be necessary to require evidence of poverty, 



and the furnishing of such evidence would itself constitute a burden on the exercise 



of the franchise.'"  Reply Br. of Resp'ts/Cross-Appellants at 11 (quoting Br. for the 



United States as Amicus Curiae, Harper v. Va. State Bd. of Elections, 383 U.S. 



663, 1965 WL 130114, *33).  However, the court in Harper did not explicitly adopt 



that reasoning.  Moreover, the respondents cannot argue that they are so burdened 



because the trial court already ordered that they be allowed to register to vote 



without any further qualification.      Thus, respondents have failed to prove that they 



are aggrieved parties for the purpose of bringing a cross-appeal.



       Furthermore, even if we assume that the respondents have standing, we hold 



that respondents' cross-appeal lacks merit.  Because we have determined that 



Washington's disenfranchisement scheme does not violate the constitutional rights 



of felons who are unable to pay their LFOs,  we must necessarily hold that the 



                                              33 



Madison v. State, No. 78598-8



scheme does not violate the constitutional rights of those who are able to pay their 



LFOs.



D.     The respondents are not entitled to attorney fees



       Respondents claim that they are entitled to attorney fees under 42 U.S.C. 



§ 1983 and 42 U.S.C. § 1988.  However, because we reverse the trial court and 



enforce Washington's disenfranchisement scheme as written, the respondents are 



not a prevailing party entitled to attorney fees.



                                   IV.    CONCLUSION



       We hold that Washington's disenfranchisement scheme does not violate the 



privileges and immunities clause of the Washington Constitution or the  equal 



protection clause of the United States Constitution.   It is the province of the 



legislature to determine the best policy approach for re-enfranchising Washington's 



felons.  We also hold that respondents lack standing to bring their cross-appeal and 



that they are not entitled to attorney fees.  We reverse the trial court.



                                              34 



Madison v. State, No. 78598-8



AUTHOR:

       Justice Mary E. Fairhurst



WE CONCUR:



                                                                Justice Susan Owens



       Justice Bobbe J. Bridge 



                                              35

			

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