Washington Courts' Use of Legislative History in Statutory Interpretation: An Overview with an Eye towards IFCA
![handle is hein.journals/gonlr49 and id is 477 raw text is: WASHINGTON COURTS' USE OF LEGISLATIVE HISTORY
IN STATUTORY INTERPRETATION:
AN OVERVIEW WITH AN EYE TOWARDS IFCA
Mark DeForrest*
[T]he fairest and most rational method to interpret the will of the legislator is
by exploring his intentions at the time when the law was made, by signs the
most natural and probable. And these signs are either the words, the context,
the subject-matter, the effects and consequence, or the spirit and reason of the
law.
-Sir William Blackstone'
TABLE OF CONTENTS
1. INTRODUCTION ....................................... ..... 438
II. Two PREVIOUS STUDIES OF THE USE OF LEGISLATIVE HISTORY BY
WASHINGTON COURTS ................................ ......440
A. A New Approach to Statutory Interpretation in Washington.......440
B. Legislative History in Washington................. ...... 441
III. WHAT Is LEGISLATIVE HISTORY?.........................444
A. Textual History ........................................ 444
B. Legislative Background ............................. 446
1. Pre-Enactment Materials................. ....... 446
2. Post-Enactment .................................. 450
* Associate Professor of Law-Legal Research and Writing, Gonzaga University
School of Law. J.D., 1997, Gonzaga University School of Law. B.A., 1992, Western
Washington University. The author thanks his research assistant, Elijah Marchbanks, and
Assistant Professor Kurt Meyer of the Chastek Library at Gonzaga University School of Law
for their help with some of this article's research.
I. COMMENTARIES ON THE LAWS OF ENGLAND *59 (quoted in State v. Meath, 147 P.
11, 13 (Wash. 1915)).
437](ViewImageLocal?handle=hein.journals/gonlr49&div=25&collection=&method=preview&ext=.png&size=3)
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Washington Courts' Use of Legislative History in Statutory Interpretation: An Overview with an Eye towards IFCA
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