IN THE SUPREME COURT OF THE STATE OF WASHINGTON                                                                                                       
                                                                                                                                                      
STATE OF WASHINGTON ex rel.                                                                                                                          
PUBLIC DISCLOSURE COMMISSION,                                                                                                                        
                                                                                                                                                     
          Appellant,                                                                                                                                 
                                                                                                                                                     
     v.                                                                                                                              
                                                                                                                                          
119 VOTE NO! COMMITTEE, EILEEN                                                                                                 
BROWN, Executive Director, THOMAS                                                                                                                    
FINCH, Treasurer,                                                                                                                                    
                                                                                                                                                     
          Respondents,                                                                                                                               
                                                                                                                                                     
AMERICAN CIVIL LIBERTIES UNION OF                                                                                                                    
WASHINGTON, a Washington                                                                                                                             
nonprofit corporation, on behalf                                                                                                                     
of itself and its members,                                                                                                                           
                                                                                                                                                     
          Respondents,                                                                                                                               
                                                                                                                                                     
          v.                                                                                                                                         
                                                                                                                                                     
IRENE HENINGER, JOCELYN                                                                                                                              
MARCHISIO, JIM WHITESIDE, DON                                                                                                                        
BRAZIER, and GARY MACHARA,                                                                                                                           
Commissioners, WASHINGTON STATE                                                                                                                      
PUBLIC DISCLOSURE COMMISSION, in                                                                                                                     
their official capacity; and                                                                                                                         
CHRISTINE O. GREGOIRE, Attorney                                                                                                                      
General of the State of                                                                                                                              
Washington, in her official                                                                                                                          
capacity,                                                                                                                                            
                                                                                                                                                     
          Defendants.  

No. 64332-6     		  
En Banc   		  
Filed June 11, 1998  	  
                                                                                                                                                                     
     SANDERS, J. The Public Disclosure Commission (PDC) alleges the                                                                                   
119 Vote No! Committee violated RCW 42.17.530(1)(a) by publishing false                                                                               
political advertising.  We must decide two issues: does RCW 42.17.530(1)(a)                                                                           
violate the First Amendment on its face; and, if not, did the subject                                                                                 
advertisement violate the statute.  As we conclude, RCW 42.17.530(1)(a)                                                                               
indeed facially violates the First Amendment the second question falls by                                                                             
the way.

I.   Facts

     The State of Washington on relation of the Public Disclosure                                                                                     
Commission brought suit against the 119 Vote No! Committee, its executive                                                                             
director and its treasurer.  The State alleges the Committee published                                                                                
political advertising contrary to RCW 42.17.530(1)(a) during the course of                                                                            
its campaign in opposition to Initiative 119, the so-called "Death with                                                                               
Dignity Act."  Ultimately the initiative went down to defeat at the polls                                                                             
on November 5, 1991.  The one-page printed advertisement begins with the                                                                              
words "Vote No!" superimposed over the words "Initiative 119," Clerk's                                                                                
Papers (CP) at 18, and generally suggests the initiative invites assisted                                                                             
suicide without sufficient safeguards.1 

     RCW 42.17.530(1)(a) prohibits any person from sponsoring, with actual                                                                            
malice, a political advertisement containing a false statement of material                                                                            
fact.2  The State's complaint alleged the advertisement distributed by the                                                                            
Committee "contained false statements of material fact, and was published                                                                             
by the Committee with actual malice, that is, with knowledge that the                                                                                 
statements contained in the advertisement were false or in reckless                                                                                   
disregard of whether the statements were false."  CP at 6.  The PDC's                                                                                 
referral arose from a complaint filed by proponents of the initiative.  The                                                                           
State's complaint prayed the Committee and individual defendants be fined                                                                             
up to $10,000 plus costs, attorney fees, and treble damages.

     The Committee moved to dismiss for failure to state a claim for which                                                                            
relief could be granted.  CR 12(b)(6).  The American Civil Liberties Union                                                                            
of Washington (ACLU) intervened pursuant to CR 24 to challenge the facial                                                                             
constitutionality of RCW 42.17.530(1)(a) by declaratory judgment.3
Following briefing and argument, the trial court concluded the                                                                                   
advertisement did not contain materially false statements and dismissed.                                                                              
The trial court awarded the Committee attorney fees and costs pursuant to                                                                             
RCW 42.17.400(5).4  

     Notwithstanding dismissal of the principal action against the                                                                                    
Committee, the ACLU pursued its claim for a declaratory judgment of                                                                                   
invalidity.5  The ACLU and the State cross-moved for summary judgment each                                                                            
seeking a declaration as to the statute's constitutionality under the First                                                                           
Amendment.  On stipulated facts concerning the enforcement of RCW                                                                                     
42.17.530(1)(a) the court granted the State's motion, concluding the                                                                                  
statute facially passed First Amendment muster.  Both parties appealed.  We                                                                           
granted direct review.

 II. Standard of Review
 
     "Under CR 12(b)(6), a complaint can be dismissed if it fails to state                                                                            
a claim upon which relief can be granted.  Because a trial court's                                                                                    
dismissal under this rule is a holding on a question of law, appellate                                                                                
review is de novo."  Hoffer v. State, 110 Wn.2d 415, 420, 755 P.2d 781                                                                                
(1988).  Likewise, the facial constitutionality of a statute is a question                                                                            
of law which requires de novo review.  Timberline Air Serv. Inc. v. Bell                                                                              
Helicopter-Textron, Inc., 125 Wn.2d 305, 311, 884 P.2d 920 (1994).

III. Legal Analysis 

     RCW 42.17.530(1)(a) provides:  "It is a violation of this chapter for                                                                            
a person to sponsor with actual malice . . . {p}olitical advertising that                                                                             
contains a false statement of material fact . . . ."  The Committee and the                                                                           
ACLU argue the statute is a facially unconstitutional abridgment of free                                                                              
speech.  The State asserts its interest in an informed electorate justifies                                                                           
this burden upon political debate.

     The constitutional guarantee of free speech has its "fullest and most                                                                            
urgent application" in political campaigns.  Brown v. Hartlage, 456 U.S.                                                                              
45, 53, 102 S. Ct. 1523, 71 L. Ed. 2d 732 (1982) (quoting Monitor Patriot                                                                             
Co. v. Roy, 401 U.S. 265, 271-72, 91 S. Ct. 621, 28 L. Ed. 2d 35 (1971)).                                                                             
Therefore, the State bears a "well-nigh insurmountable" burden to justify                                                                             
RCW 42.17.530's restriction on political speech.  Meyer v. Grant, 486 U.S.                                                                            
414, 425, 108 S. Ct. 1886, 100 L. Ed. 2d 425 (1988).  This burden requires                                                                            
the court to apply "exacting scrutiny" to RCW 42.17.530(1)(a).  Meyer, 486                                                                            
U.S. at 420.  See also Buckley v. Valeo, 424 U.S. 1, 39, 96 S. Ct. 612, 46                                                                            
L. Ed. 2d 659 (1976).  Exacting scrutiny will invalidate the statute unless                                                                           
the State demonstrates a compelling interest that is both narrowly tailored                                                                           
and necessary.  McIntyre v. Ohio Elections Comm'n, 514 U.S. 334, 347, 115                                                                             
S. Ct. 1511, 1519, 131 L. Ed. 2d 426 (1995); Burson v. Freeman, 504 U.S.                                                                              
191, 198, 112 S. Ct. 1846, 119 L. Ed. 2d 5 (1992).  Such burdens are rarely                                                                           
met.  Burson, 504 U.S. at 199-200.  Ino Ino, Inc. v. City of Bellevue, 132                                                                            
Wn.2d 103, 114, 937 P.2d 154 (1997) ("The State bears the burden of                                                                              
justifying a restriction on speech.").

A.   RCW 42.17.530(1)(a) infringes on speech protected                                                                                                
by the First Amendment                                                                                                                           
                                                                                                                                                      
     Uninhibited speech "`is the single most important element upon which                                                                             
this nation has thrived.'"  Nelson v. McClatchy Newspapers, Inc., 131 Wn.2d                                                                           
523, 536, 936 P.2d 1123 (quoting Guzick v. Drebus, 305 F. Supp. 472, 481                                                                              
(N.D. Ohio 1969), aff'd, 431 F.2d 594 (6th Cir. 1970), cert. denied, 401                                                                              
U.S. 948, 91 S. Ct. 941, 28 L. Ed. 2d 231 (1971)), cert. denied, 118 S. Ct.                                                                           
175 (1997).  Free speech is revered as the "Constitution's majestic                                                                                   
guarantee," central to the preservation of all other rights.  Id. at 536.                                                                             
Advocacy of one's political views through leafleting lies at the very core                                                                            
of our First Amendment freedoms.  McIntyre, 514 U.S. at 346-47; Meyer, 486                                                                            
U.S. at 421-22. 

     The State asserts it may prohibit false statements of fact contained                                                                             
in political advertisements.  This claim presupposes the State possesses an                                                                           
independent right to determine truth and falsity in political debate.                                                                                 
However, the courts have "consistently refused to recognize an exception                                                                              
for any test of truth whether administered by judges, juries, or                                                                                      
administrative officials and especially one that puts the burden of proving                                                                           
truth on the speaker."  New York Times Co. v. Sullivan, 376 U.S. 254, 271,                                                                            
84 S. Ct. 710, 11 L. Ed. 2d 686, 95 A.L.R.2d 1412 (1964).

     Rather, the First Amendment operates to insure the public decides what                                                                           
is true and false with respect to governance.  Meyer, 486 U.S. at 419-20;                                                                             
Riley v. National Fed. of the Blind of North Carolina, Inc., 487 U.S. 781,                                                                            
791, 108 S. Ct. 2667, 101 L. Ed. 2d 669 (1988).  In Meyer, the Supreme                                                                                
Court explained:

     "`The very purpose of the First Amendment is to foreclose public                                                                                 
     authority from assuming a guardianship of the public mind . . . .                                                                                
     In this field every person must be his own watchman for truth,                                                                                   
     because the forefathers did not trust any government to separate                                                                                 
     the true from the false for us.'  Thomas v. Collins, {323 U.S.                                                                                   
     516, 545 (1945)} (Jackson, J., concurring)}."  {Grant v. Meyer,                                                                                  
     828 F.2d 1446, 1455 (10th Cir. 1987)}.                                                                                                           
                                                                                                                                                      
Meyer, 486 U.S. at 419-20 (emphasis added).                                                                                                           
                                                                                                                                                      
     Particularly in the religious and political realms, "the tenets of one                                                                           
man . . . seem the rankest error to his neighbor."  Cantwell v.                                                                                       
Connecticut, 310 U.S. 296, 310, 60 S. Ct. 900, 84 L. Ed. 2d 1213, 128                                                                                 
A.L.R. 1352 (1940).  Therefore, the Supreme Court has recognized that to                                                                              
sustain our constitutional commitment to uninhibited political discourse,                                                                             
the State may not prevent others from "resort{ing} to exaggeration, to                                                                                
vilification of men who have been, or are, prominent in church and state,                                                                             
and even to false statement."  Id. (emphasis added).  At times such speech                                                                            
seems unpalatable, but the value of free debate overcomes the danger of                                                                               
misuse.  McIntyre, 514 U.S. at 357.  For even false statements make                                                                                   
valuable contributions to debate by bringing about "the clearer perception                                                                            
and livelier impression of truth, produced by its collision with error."                                                                              
New York Times, 376 U.S. at 279 n.19 (quoting John S. Mill, On Liberty 15                                                                             
(Oxford, Blackwell 1947)).

     Specifically, the First Amendment prohibits the State from silencing                                                                             
speech it disapproves, particularly silencing criticism of government                                                                                 
itself.  Threats of coerced silence chill uninhibited political debate and                                                                            
undermine the very purpose of the First Amendment.  See Riley, 487 U.S. at                                                                            
791; Brown, 456 U.S. at 61; Meyer, 486 U.S. at 419-20.

     {The Founders of the nation} believed that freedom to think as                                                                                   
     you will and speak as you think are means indispensable to the                                                                                   
     discovery and spread of political truth. . . .  Believing in the                                                                                 
     power of reason as applied through the public discussion, they                                                                                   
     eschewed silence coerced by law -- the argument of force in its                                                                                  
     worst form.                                                                                                                                      
                                                                                                                                                      
Whitney v. California, 274 U.S. 357, 375-76, 47 S. Ct. 641, 71 L. Ed. 1095                                                                            
(1927) (Brandeis, J., concurring), overruled on other grounds by                                                                                      
Brandenburg v. Ohio, 395 U.S. 444, 89 S. Ct. 1827, 23 L. Ed. 2d 430 (1969).                                                                           
See also New York Times, 376 U.S. at 270.  The State cannot "substitute its                                                                           
judgment as to how best to speak for that of speakers and listeners; free                                                                             
and robust debate cannot thrive if directed by the government."  Riley, 487                                                                           
U.S. at 791.  "For speech concerning public affairs is more than self-                                                                                
expression; it is the essence of self government."  Garrison v. Louisiana,                                                                            
379 U.S. 64, 74-75, 85 S. Ct. 209, 13 L. Ed. 2d 125 (1964), overruled on                                                                              
other grounds sub nom. by Curtis Publ'g Co. v. Butts, 388 U.S. 130, 87 S.                                                                             
Ct. 1975, 18 L. Ed. 2d 1094 (1967). 

     Instead of relying on the State to silence false political speech, the                                                                           
First Amendment requires our dependence on even more speech to bring forth                                                                            
truth.  Brown, 456 U.S. at 61.  See also Gertz v. Robert Welch, Inc., 418                                                                             
U.S. 323, 339-40, 94 S. Ct. 2997, 41 L. Ed. 2d 789 (1974).  In the                                                                                    
political context, a campaign's factual blunder is most likely noticed and                                                                            
corrected by the campaign's political opponent rather than the State.  Id.                                                                            
Contrary to claims made by Justice Talmadge in his concurrence, the Supreme                                                                           
Court has refused to recognize the possibility of "`an eleventh-hour                                                                                  
anonymous smear campaign'" as enough to justify a restriction on speech.                                                                              
McIntyre, 514 U.S. at 352 n.16 (quoting People v. White, 116 Ill. 2d 171,                                                                             
506 N.E.2d 1284, 1288, 107 Ill. Dec. 229 (1987)).  Moreover, a well-                                                                                  
publicized, yet bogus, complaint to the PDC on election eve raises the same                                                                           
concern.  Therefore, "{t}he preferred First Amendment remedy of `more                                                                                 
speech, not enforced silence' thus has special force."  Brown v. Hartlage,                                                                            
456 U.S. 45, 61, 102 S. Ct. 1523, 1533, 71 L. Ed. 2d 732 (1982) (citation                                                                             
omitted).  Underlying our dependence upon more speech is the presupposition                                                                           
"that right conclusions are more likely to be gathered out of a multitude                                                                             
of tongues, than through any kind of authoritative selection.  To many this                                                                           
is, and always will be, folly; but we have staked upon it our all.'"  New                                                                             
York Times, 376 U.S. at 270 (quoting United States v. Associated Press, 52                                                                            
F. Supp. 362, 372 (S.D.N.Y. 1943)). 

     RCW 42.17.530 coerces silence by force of law and presupposes the                                                                                
State will "separate the truth from the false" for the citizenry.  The                                                                                
government made a similar attempt to suppress "seditious libel" in the                                                                                
Sedition Act of 1798, 1 Stat. 596.  New York Times, 376 U.S. at 273.  That                                                                            
Act made it a crime for any person to write, print, utter or publish any                                                                              
false writings against the government.  Id. at 273-74 (quoting 1 Stat.                                                                                
596).  The Act was vigorously condemned as unconstitutional because it                                                                                
inevitably chilled that political debate needed for self-governance;                                                                                  
however, it was allowed to expire by its own terms in 1801 before judicial                                                                            
challenge.6  Id. at 274, 276.  The First Amendment exists precisely to                                                                                
protect against laws such as RCW 42.17.530(1)(a) which suppress ideas and                                                                        
inhibit free discussion of governmental affairs.  See McIntyre, 514 U.S. at                                                                           
357; Mills v. Alabama, 384 U.S. 214, 218, 86 S. Ct. 1434, 16 L. Ed. 2d 484                                                                            
(1966). 

     Even assuming, as per Justice Talmadge's concurrence, that malicious                                                                             
falsehoods against candidates are beyond constitutional protection, this                                                                              
statute has broader reach and brings within its sweep every maliciously                                                                               
false statement of "material fact" whether it is defamatory to an                                                                                     
individual or not.  Justice Talmadge's concurrence cites no authority to                                                                              
support its broad claim that all false statements in a political                                                                                      
advertisement, including statements relating to issues campaigns, may be                                                                              
prohibited as unprotected speech.  Moreover, the statutory requirement that                                                                           
malice be proved by a high standard of proof does not cure the infirmity as                                                                           
the chilling effect of possible governmental sanction will not be lost on                                                                             
the faint of heart.

B.   RCW 42.17.530(1)(a) does not serve a compelling state interest

     Because RCW 42.17.530(1)(a) infringes upon protected speech, the court                                                                           
must apply "exacting scrutiny."  The State bears the "well-nigh                                                                                       
insurmountable" burden to prove a compelling interest that is both narrowly                                                                           
tailored and necessary to achieve the State's asserted interest.  McIntyre                                                                            
v. Ohio Elections Comm'n, 514 U.S. 334, 347, 115 S. Ct. 1511, 1519, 131 L.                                                                            
Ed. 2d 426 (1995); Burson, 504 U.S. at 198.  States rarely meet this heavy                                                                            
burden.  Burson, 504 U.S. at 199-200. 

The State claims its interest to foster an informed electorate outweighs                                                                              
the imposition upon political expression by RCW 42.17.530(1)(a).  The State                                                                           
relies heavily on defamation cases to prove a compelling interest to                                                                                  
justify intrusion into public debate citing Gertz, 418 U.S. at 340, which                                                                             
states:  "{T}here is no constitutional value in false statements of fact.                                                                             
Neither the intentional lie nor the careless error materially advances                                                                                
society's interest in `uninhibited, robust, and wide-open' debate on public                                                                           
issues."  See also Garrison, 379 U.S. at 75 (quoting New York Times Co.,                                                                              
376 U.S. at 270).  The State argues the language in these defamation cases                                                                            
applies with equal force to all political speech, even if no one is                                                                                   
defamed.7 

     However the State's reliance on the law of defamation is misplaced.                                                                              
By its nature defamation concerns statements made by one person against                                                                               
another and is designed to protect the property of an individual in his or                                                                            
her good name. 

          The legitimate state interest underlying the law of libel is                                                                                
     the compensation of individuals for the harm inflicted on them by                                                                                
     a defamatory falsehood. . . .  {T}he individual's right to the                                                                                   
     protection of his own good name "reflects no more than our basic                                                                                 
     concept of the essential dignity and worth of every human being a                                                                                
     concept at the root of any decent system of ordered liberty."                                                                                    
                                                                                                                                                      
Gertz, 418 U.S. at 341 (quoting Rosenblatt v. Baer, 383 U.S. 75, 92, 86 S.                                                                            
Ct. 669, 15 L. Ed. 2d 597 (1966) (Stewart, J., concurring)).  Clearly, a                                                                              
competing interest exists in defamation cases which is absent here.  As                                                                               
then-Professor Fried explained: 

     Free speech cases often explain that "{t}here is no such thing as                                                                                
     a false idea."  But why may the state intervene to prohibit or                                                                                   
     punish factually false statements?  Defamation and deception are                                                                                 
     actionable wrongs, perhaps on the reasoning I have already                                                                                       
     offered:  they vindicate private rights invoked by, or at least                                                                                  
     on behalf of, private individuals.  But the First Amendment                                                                                      
     precludes punishment for generalized "public" frauds, deceptions                                                                                 
     and defamation.  In political campaigns the grossest                                                                                             
     misstatements, deceptions, and defamations are immune from legal                                                                                 
     sanction unless they violate private rights that is, unless                                                                                      
     individuals are defamed.{8}                                                                                                                      
                                                                                                                                                      
Charles Fried, The New First Amendment Jurisprudence: A Threat to Liberty,                                                                            
59 U. Chi. L. Rev. 225, 238 (1992) (footnotes omitted). 

     However RCW 42.17.530(1)(a) restricts political speech absent the                                                                                
competing interest present in defamation cases, and, unlike a defamation                                                                              
suit, creates a cause of action for the government to pursue against a                                                                                
private person.  "The legitimate state interest underlying the law of libel                                                                           
is the compensation of individuals for the harm inflicted on them for                                                                                 
defamatory falsehood."  Gertz, 418 U.S. at 341.  See also Rosenblatt, 383                                                                             
U.S. at 93 ("{A}n action for damages is the only hope for vindication or                                                                              
redress the law gives to a man whose reputation has been falsely                                                                                      
dishonored.").

     Additionally, the State relies upon the United States Supreme Court's                                                                            
decision in McIntyre, as well as this court's decision in In re Donohoe, 90                                                                           
Wn.2d 173, 580 P.2d 1093 (1978), to support its contention that it has a                                                                              
compelling interest to regulate maliciously false speech.  But neither case                                                                           
supports its claim. 

     In McIntyre the Supreme Court held a statute prohibiting anonymous                                                                               
leaflets violated the First Amendment.  The Court noted Ohio's Elections                                                                              
Code contained detailed prohibitions against making false statements.  514                                                                            
U.S. at 349.  Therefore the State asserts McIntyre impliedly suggested laws                                                                           
prohibiting false political statements are constitutional.

     However the inference to be drawn from McIntyre is just the opposite.                                                                            
McIntyre explained that speech made in the heat of a political contest                                                                                
receives more protection than any other form of political speech.  Id. at                                                                             
347.  The state in McIntyre argued the speech restrictions were necessary                                                                             
because false advertising might be distributed as "an eleventh-hour                                                                                   
anonymous smear campaign." Id. at 353 n.16.  The Court explained the                                                                                  
statute could not be upheld on that ground because it swept within it                                                                                 
speech unrelated to the state's concern.  Id.  Describing the statute's                                                                               
unconstitutional breadth, the Court distinguished between literature                                                                             
supporting or opposing candidates from referenda as "{a} public question                                                                              
clearly cannot be the victim of character assassination."  Id.  McIntyre                                                                              
indicates the State does not possess an independent right to determine                                                                                
truth and falsity in public issues.9

     In Donohoe a judicial candidate made numerous allegedly false                                                                                    
statements regarding incumbent judges.  The Court disciplined the candidate                                                                           
claiming the State possessed a unique interest in maintaining the integrity                                                                           
of the judiciary.  90 Wn.2d at 180.  However the continuing viability of                                                                              
this precedent is questionable in light of more recent authority which                                                                                
prompted 1995 revisions to the Code of Judicial Conduct.  See, e.g.,                                                                                  
Buckley v. Illinois Judicial Inquiry Bd., 997 F.2d 224 (7th Cir. 1993).                                                                               
Justice Talmadge's concurrence quotes Burson v. Freeman, 504 U.S. at 199-                                                                             
200, to suggest the State possesses a compelling interest in "ensuring the                                                                            
integrity of the electoral process."  Concurrence (Talmadge, J.) at 21.                                                                               
However, Burson is distinguishable as the statute there dealt with whether                                                                            
campaign materials could be displayed near the entrance to a polling place.                                                                           
The Court did not find a compelling interest to allow the State to                                                                                    
determine the truth and falsity of political speech on campaign issues.                                                                               
Moreover, the false statements in Donohoe were directed at another                                                                                    
candidate, not statements in an initiative campaign as is the case here.

     Additionally, even if the State possessed a compelling interest here,                                                                            
it must also prove the statute at issue is necessary to serve that                                                                                    
interest.  Burson, 504 U.S. at 199-200.  However, the record here                                                                                     
demonstrates RCW 42.17.530(1)(a) may be manipulated by candidates to impugn                                                                           
the electoral process rather than promote truthfulness. 

     Ultimately, the State's claimed compelling interest to shield the                                                                                
public from falsehoods during a political campaign is patronizing and                                                                                 
paternalistic.10  See Eu v. San Francisco County Democratic Cent. Comm., 489                                                                          
U.S. 214, 223-24, 109 S. Ct. 1013, 103 L. Ed. 2d 271 (1989); Brown, 456                                                                               
U.S. at 61.  It assumes the people of this state are too ignorant or                                                                                  
disinterested to investigate, learn, and determine for themselves the truth                                                                           
or falsity in political debate, and it is the proper role of the government                                                                           
itself to fill the void.  This assumption is especially flawed in cases                                                                               
like this where the truth of the assertion may be readily tested against                                                                              
the text of the initiative.  At its worst the statute is pure censorship,                                                                             
allowing government to undertake prosecution of citizens who, in their                                                                                
view, have abused the right of political debate.
	 
     We therefore conclude RCW 42.17.530(1)(a) chills political speech,                                                                               
usurps the rights of the electorate to determine the merits of political                                                                              
initiatives without fear of government sanction, and lacks a compelling                                                                               
state interest in justification.

      IV. Conclusion
	  
     The First Amendment to the United States Constitution renders RCW                                                                                
42.17.530(1)(a) facially unconstitutional.  The ACLU is awarded its                                                                                   
reasonable attorney fees pursuant to 42 U.S.C.  1988 and the 119 Vote No!                                                                             
Committee is awarded its reasonably attorney fees pursuant to RCW                                                                                     
42.17.400(5).                                                                                                                                         
                                                                                                                                                      
     WE CONCUR:  
	 
	 
FOOTNOTES	 
                                                                                                                                                      
1 The leaflet stated in pertinent part:                                                                                                               
                                                                                                                                                      
Initiative 119:  Vote No                                                                                                                              
                                                                                                                                                      
IT WOULD LET DOCTORS END PATIENTS' LIVES WITHOUT BENEFIT OF SAFEGUARDS . .                                                                            
.                                                                                                                                                     
                                                                                                                                                      
     Ü  No special qualifications--                                                                                                                   
                                                                                                                                                      
         your eye doctor could kill you.                                                                                                              
                                                                                                                                                      
     Ü  No rules against coercion--                                                                                                                   
                                                                                                                                                      
         Nothing to prevent "selling" the idea to the aged, the poor,                                                                                 
the homeless.                                                                                                                                         
                                                                                                                                                      
     Ü  No reporting requirements--                                                                                                                   
                                                                                                                                                      
        No records kept.                                                                                                                              
                                                                                                                                                      
     Ü  No notification requirements--                                                                                                                
                                                                                                                                                      
         Nobody need tell family members beforehand.                                                                                                  
                                                                                                                                                      
     Ü   No protection for the depressed--                                                                                                            
                                                                                                                                                      
          No waiting period, no chance to change your mind.                                                                                           
                                                                                                                                                      
INITIATIVE 119 . . . IS A DANGEROUS LAW                                                                                                               
                                                                                                                                                      
VOTE NO ON INITIATIVE 119                                                                                                                             
                                                                                                                                                      
Clerk's Papers (CP) at 18.                                                                                                                            
                                                                                                                                                      
2 RCW 42.17.530 provides:                                                                                                                             
                                                                                                                                                      
False political advertising                                                                                                                           
                                                                                                                                                      
     (1)  It is a violation of this chapter for a person to sponsor with                                                                              
actual malice:                                                                                                                                        
                                                                                                                                                      
          (a)  Political advertising that contains a false statement of                                                                               
material fact;                                                                                                                                        
                                                                                                                                                      
          (b)  Political advertising that falsely represents that a                                                                                   
candidate is the incumbent for the office sought when in fact the candidate                                                                           
is not the incumbent;                                                                                                                                 
                                                                                                                                                      
          (c)  Political advertising that makes either directly or                                                                                    
indirectly, a false claim stating or implying the support or endorsement of                                                                           
any person or organization when in fact the candidate does not have such                                                                              
support or endorsement.                                                                                                                               
                                                                                                                                                      
          (2)  Any violation of this section shall be proven by clear and                                                                             
convincing evidence.                                                                                                                                  
                                                                                                                                                      
3 The ACLU has standing to assert its claim on its own behalf.  A statute                                                                             
that chills a plaintiff's speech grants standing to that plaintiff and                                                                                
presents a case ripe for adjudication.  A plaintiff need not "expose                                                                                  
himself to actual arrest or prosecution" to challenge a statute which                                                                                 
deters the exercise of his constitutional rights.  Steffel v. Thompson, 415                                                                           
U.S. 452, 459, 94 S. Ct. 1209, 39 L. Ed. 2d 505 (1974).  New York Civil                                                                               
Liberties Union, Inc. v. Acito, 459 F. Supp. 75, 81-82 (S.D.N.Y. 1978)                                                                                
("{The plaintiffs} contend that the existence of the statute, in its                                                                                  
present form, leaves forever open the possibility of enforcement against                                                                              
them as well as other non-partisan, non-political groups . . .  The                                                                                   
potential for such a situation, with its clear likelihood of causing                                                                                  
chilling effects upon plaintiffs, leads us to conclude . . . that the  . .                                                                            
. questions are ripe for declaratory action.") (quoting American Civil                                                                                
Liberties Union, Inc. v. Jennings, 366 F. Supp. 1041, 1048 (D.D.C. 1973));                                                                            
Walker v. Munro, 124 Wn.2d 402, 416, 879 P.2d 920 (1994) ("In the First                                                                               
Amendment context, a `chilling effect' on First Amendment rights is a                                                                                 
recognized present harm, not a future speculative harm, which allows third                                                                            
party standing when the law in question burdens constitutionally protected                                                                            
conduct.").                                                                                                                                           
                                                                                                                                                      
     The ACLU engages in the support and opposition of referenda and                                                                                  
initiatives, as attested to by the fact they publicly supported Initiative                                                                            
119.  ACLU Br. at 3 n.1.  Thus, they themselves are presented with the                                                                                
choice of either risking prosecution under the statute or preemptively                                                                                
tempering their public advertisements concerning proposed initiatives.                                                                                
This Hobson's choice clearly grants standing to prosecute a declaratory                                                                               
action against the facial unconstitutionality of RCW 42.17.530(1)(a).                                                                                 
                                                                                                                                                      
4 The trial court also awarded attorney fees and costs to the ACLU under 42                                                                           
U.S.C.  1988 because the ACLU successfully prevailed on its claims that the                                                                           
Constitution does not permit the PDC to issue administrative restraints on                                                                            
political speech and that there must be a final determination on the merits                                                                           
before a court may restrain any political speech.  The State does not                                                                                 
appeal these determinations by the trial court.                                                                                                       
                                                                                                                                                      
5 The ACLU may prosecute its complaint after the trial court dismissed the                                                                            
original, underlying suit.  State v. Port of Peninsula, 89 Wn.2d 764, 767,                                                                            
575 P.2d 713 (1978) (The court has "discretion to retain an intervenor's                                                                              
suit as a separate action, even if the main action falls.").                                                                                          
                                                                                                                                                      
6 Before ascending to the bench Chief Justice John Marshall publicly                                                                                  
opposed the acts and pledged, if elected to Congress, that he would                                                                                   
"indisputably oppose their revival" without regard to constitutionality.                                                                              
Jean Edward Smith, John Marshall, Definer of a Nation 244 (1996).                                                                                     
                                                                                                                                                      
7 The State attempts to bootstrap its compelling interest argument by                                                                                 
claiming the interest is more compelling alleging the speech here is                                                                                  
unprotected.  As discussed earlier, RCW 42.17.530(1)(a) impacts protected                                                                             
speech and the discussion concerning compelling interest only further                                                                                 
demonstrates this.                                                                                                                                    
                                                                                                                                                      
8 Justice Talmadge's concurrence describes this statement as "flat wrong."                                                                            
Concurrence (Talmadge, J.) at 15.  However, to support its claim the                                                                                  
concurrence relies upon cases and statutes that are immaterial to Professor                                                                           
Fried's accurate analysis.  Buckley v. Valeo, 424 U.S. 1, 96 S. Ct. 612, 46                                                                           
L. Ed. 2d 659 (1976) dealt with campaign finance; Burson v. Freeman, 504                                                                              
U.S. 191, 112 S. Ct. 1846, 119 L. Ed. 2d 5 (1992) dealt with polling place                                                                            
electioneering.  RCW 29.51.020(1)(a) likewise deals with electioneering.                                                                              
What relevance any of these have to the point made by Professor Fried, and                                                                            
the issue in this case, is unclear.  Certainly they have nothing to do with                                                                           
punishment of general, nonpersonal political statements the state decides                                                                             
are "misstatements, deceptions, and defamations."                                                                                                     
                                                                                                                                                      
9 Additionally, the implication drawn by Justice Talmadge's concurrence at                                                                            
page 17 that "{t}he Court impliedly approved" statutory prohibitions                                                                                  
against making false statements is thwarted by the Court's express                                                                                    
statement declining to evaluate the constitutionality of the Ohio's                                                                                   
antifraud provisions.  McIntyre v. Ohio Elections Comm'n, 514 U.S. 334,                                                                               
351, 115 S. Ct. 1511, 131 L. Ed. 2d 426 (1995).                                                                                                       
                                                                                                                                                      
10 Justice Talmadge's concurrence claims characterizing this statute as                                                                               
"patronizing and paternalistic" is a "novel approach to constitutional                                                                                
analysis."  Concurrence (Talmadge, J.) at 25.  However, we are not alone as                                                                           
the United States Supreme Court has adopted this "novel approach" as well.                                                                            
See Eu, 489 U.S. at 223 (When the State "directly hampers the ability of a                                                                            
party to spread its message and hamstrings voters seeking to inform                                                                                   
themselves about the candidates and the campaign issues," it has adopted a                                                                            
"highly paternalistic approach" by "limiting what people may hear . . . ."                                                                            
This approach renders such a law constitutionally suspect.).                                                                                          
                                                                                                                                                      


																																				  
																																					  
     GUY, J. (concurring) The judiciary has the duty to be vigilant in                                                                                
protecting citizens from laws that chill political speech.  Calculated lies                                                                           
are not protected political speech.  The elected representatives of the                                                                               
people have a right to pass laws which make malicious lying illegal in                                                                                
political campaigns; we have no constitutional duty to strike down such                                                                               
laws.  The statute before us requires actual malice regarding a false                                                                                 
statement of material fact, and requires that such malice and materiality                                                                             
be proved in a court of law by clear and convincing evidence.  RCW                                                                                    
42.17.530(2).  I have an abiding belief in the value of "uninhibited,                                                                                 
robust, and wide-open" debate on public issues.  New York Times Co. v.                                                                                
Sullivan, 376 U.S. 254, 270, 84 S. Ct. 710, 11 L. Ed. 2d 686 (1964).                                                                                  
Intentional, malicious lies do not foster debate; they foster deception and                                                                           
manipulation of the voting public. 

     I agree with the majority and Justice Talmadge's concurrence that the                                                                            
advertisement before us from the 119 Vote No! Committee does not violate                                                                              
RCW 42.17.530(1)(a).  I disagree with the majority and Justice Madsen's                                                                               
concurrence that the statute on its face violates the First Amendment.                                                                                



     MADSEN, J.  (concurring)  --  I agree with the majority that RCW                                                                                 
 42.17.530 is facially unconstitutional because it sweeps protected First                                                                              
 Amendment activity within its provisions by penalizing political speech,                                                                              
 even if knowingly false, regarding an initiative measure.  I write                                                                                    
 separately to emphasize that I am not convinced that the same is true where                                                                           
 a statement contains deliberate falsehoods about a candidate for public                                                                               
 office.  In my view, there is merit to the contention that the Legislature                                                                            
 may constitutionally penalize sponsorship of political advertising of such                                                                            
 a nature by enacting a narrower statute than RCW 42.17.530.
 
  In New York Times Co. v. Sullivan, 376 U.S. 254, 279-80, 84 S. Ct.                                                                               
 710, 11 L. Ed.2d 686, 95 A.L.R. 2d 1412 (1964), the Court held that under the First and                                                                             
 Fourteenth Amendments a public official is prohibited from "recovering
 damages for a defamatory falsehood relating to his official conduct unless                                                                            
 he proves that the statement was made with `actual malice' -- that is, with                                                                           
 knowledge that it was false or with reckless disregard of whether it was                                                                              
 false or not."  The Court soon refined the "official conduct" rule to                                                                                 
 include "anything which might touch on an official's fitness for office."                                                                             
 Garrison v. Louisiana, 379 U. S. 64, 77, 85 S. Ct. 209, 13 L. Ed. 2d 125                                                                              
 (1964), overruled on other grounds by Curtis Publ'g Co. v. Butts, 388 U.S.                                                                            
 130, 87 S. Ct. 1975, 18 L. Ed. 2d 1094 (1967).  The New York Times rule,                                                                              
 the Court said, is "based on a recognition that the First Amendment                                                                                   
 guarantee of a free press is inevitably in tension with state libel laws                                                                              
 designed to secure society's interest in the protection of individual                                                                                 
 reputation."  Monitor Patriot Co. v. Roy, 401 U.S. 265, 270, 91 S. Ct. 621,                                                                           
 28 L. Ed. 2d 35 (1971).  This interest in reputation is what distinguishes                                                                            
 speech concerning an initiative measure, which the majority correctly holds
 is protected even if knowingly false, and speech regarding individuals.
 
      In Monitor Patriot, the Court held that the New York Times rule                                                                                  
 applies in the case of statements criticizing a candidate for public                                                                                  
 office.  "{I}t is abundantly clear that . . . publications concerning                                                                                 
 candidates must be accorded at least as much protection under the First and                                                                           
 Fourteenth Amendments as those concerning occupants of public office."  Id.                                                                           
 at 271;1 see also Oscala Star-Banner Co. v. Damron, 401 U.S. 295, 91 S. Ct.                                                                           
 628, 28 L. Ed. 2d 57 (1971) (holding that plaintiff in capacity as                                                                                    
 candidate for county tax assessor was public official for purposes of New                                                                             
 York Times rule in defamation action against newspaper which published                                                                                
 false story that he had been indicted for perjury in a civil rights suit);                                                                            
 Brown v. Herald Co., 698 F.2d 949 (8th Cir. 1983) (candidate running for                                                                              
 office of sheriff is public official subject to New York Times rule).  The                                                                            
 Court reasoned:  "{I}f it be conceded that the First Amendment was                                                                                    
 `fashioned to assure the unfettered interchange of ideas for the bringing                                                                             
 about of political and social changes desired by the people,' Roth v.                                                                                 
 United States, 354 U.S. 476, 484{, 77 S. Ct. 1304, 1308, 1 L. Ed. 2d 1498                                                                             
 (1957)}, then it can hardly be doubted that the constitutional guarantee                                                                              
 has its fullest and most urgent application precisely to the conduct of                                                                               
 campaigns for political office."  Monitor Patriot, 401 U.S. at 271-72.
 
      The Court's decisions in New York Times and Monitor Patriot, and other                                                                           
 cases, have primarily addressed the extent to which speech is protected.                                                                              
 The other side of the coin, of course, is that where the actual malice                                                                                
 standard is met, speech may subject the speaker to pay damages without                                                                                
 running afoul of the First Amendment.  Thus, statements about candidates                                                                              
 for public office made with actual knowledge of falsity or with reckless                                                                              
 disregard of whether they are true or false are not protected under the                                                                                  First and Fourteenth Amendments.  A state, in short,  may allow recovery of                                                                           
 damages for defamation to public officials, including candidates for public                                                                           
 office, provided that the New York Times actual malice standard is                                                                                    
 satisfied.  Accordingly, although there is no case directly on point, it is                                                                           
 reasonable to contend that the Legislature could enact a law prohibiting a                                                                            
 person from sponsoring with actual malice political advertising containing                                                                            
 false statements of material fact about a candidate for public office.
 
      We need not, however, decide that issue because where an initiative                                                                              
 measure is involved, as in this case, the First Amendment does not permit                                                                             
 governmental censorship of political speech.  There must be no impediment                                                                             
 to free and open debate regarding such issues.  For unlike the case where                                                                             
 the societal interest in individual reputations is at stake, there is no                                                                              
 competing interest sufficient to override our precious freedom to                                                                                     
 vigorously debate the wisdom of enacting a measure, even if that debate                                                                               
 contains falsehoods as well as truths.2  The voters in this state are able                                                                            
 to make an informed choice based upon freely advanced competing ideas,                                                                                
 sorting the wheat from the chaff, and can compare what they hear and read 
 with the text of a proposed measure.                                                                                          
                                                                                                                                                


FOOTNOTES


 1 The Court also recognized:
 
 	The principal activity of a candidate in our political system, his                                                                                    
 	"office," so to speak, consists in putting before the voters every                                                                                    
 	conceivable aspect of his public and private life that he thinks may lead                                                                             
 	the electorate to gain a good impression of him.  A candidate who, for                                                                                
 	example, seeks to further his cause through the prominent display of his                                                                              
 	wife and children can hardly argue that his qualities as a husband or                                                                                 
 	father remain of "purely private" concern.  And the candidate who vaunts                                                                              
 	his spotless record and sterling integrity cannot convincingly cry "Foul!"                                                                            
 	when an opponent or an industrious reporter attempts to demonstrate the                                                                               
 	contrary.  Any test adequate to safeguard First Amendment guarantees in                                                                               
 	this area must go far beyond the customary meaning of the phrase "official                                                                            
 	conduct." 
 	
 Monitor Patriot Co. v. Roy, 401 U.S. 265, 274, 91 S. Ct. 621, 28 L. Ed. 2d                                                                            
 35 (1971) (footnote omitted). 
 
 2 Cf. Citizens Against Rent Control/Coalition for Fair Hous. v. City of                                                                               
 Berkeley, 454 U.S. 290, 297-98, 102 S. Ct. 434, 70 L. Ed. 2d 492 (1981)                                                                               
 (drawing a distinction for First Amendment purposes between candidates'                                                                               
 election campaigns and ballot measure campaigns; First Amendment standard                                                                             
 for core political speech prohibits the states from limiting the dollar                                                                               
 amounts of contributions for and against ballot measures in order to                                                                                  
 "equalize" the information presented on both sides, unlike the situation                                                                              
 where the governmental interest in avoiding danger of corrupt officeholders                                                                           
 is sufficient to justify limits on contributions to a candidate's                                                                                     
 election).                                                                                                                                            
                                                                                                                                                       
 


                                                                                                                                         
                                                                                                                                                       
      TALMADGE, J. (concurring) -- Today the Washington State Supreme Court                                                                            
 becomes the first court in the history of the Republic to declare First                                                                               
 Amendment protection for calculated lies.  In so doing, the majority                                                                                  
 opinion flouts numerous United States Supreme Court pronouncements to the                                                                             
 contrary.  The majority determines RCW 42.17.530, a statute providing                                                                                 
 penalties for dissemination of false political advertising, is facially                                                                               
 violative of the First Amendment because the State has no compelling                                                                                  
 interest in preventing lies in the course of an initiative or referendum                                                                              
 campaign, no matter how egregious the lies may be.
 
      The sweep of the majority's rhetoric is so encompassing that no                                                                                  
 statute designed to ensure statements of fact in political campaigns are                                                                              
 truthful would survive a First Amendment challenge.  Moreover, the breadth                                                                            
 of the majority's rhetoric has untold impacts on existing law regarding                                                                               
 political campaigns for candidates and ballot measures. 
 
      The majority is also shockingly oblivious to the increasing nastiness                                                                            
 of modern American political campaigns.  This trend is highlighted by a                                                                               
 "win at any cost" attitude involving vilification of opponents and their                                                                              
 ideas.  This new type of campaign neither illuminates nor exemplifies the                                                                             
 best of our democratic tradition, and has caused too many of our fellow                                                                               
 citizens to turn away from participation in the political process. 
 
      While I believe the First Amendment properly presents extraordinarily                                                                            
 difficult hurdles for statutes addressing political speech and conduct, I                                                                             
 cannot agree RCW 42.17.530 violates the First Amendment.  However, because                                                                            
 I believe the 119 Vote No! Committee (Committee) did not violate RCW                                                                                  
 42.17.530(1)(a), I concur in the majority's disposition of the case.
 
 ANALYSIS
 
      In view of the majority's pioneering foray into uncharted First                                                                                  
 Amendment territory, one might expect an extensive legal discussion                                                                                   
 explaining what new and original insights led it to this understanding.                                                                               
 Instead, the majority opinion consists largely of a collage of quotes                                                                                 
 extolling the virtues of free speech, propositions with which no one                                                                                  
 disagrees, and then concludes summarily the challenged statute fails the                                                                              
 First Amendment test.  Given the uniqueness of the majority's conclusion,                                                                             
 more rigorous constitutional analysis is certainly required.
 
 A.   Standard of Review
 
      The issue at bar has reached us on cross-motions for summary judgment.                                                                           
 We decide appeals from summary judgments de novo.  Because this case                                                                                  
 involves a First Amendment challenge to a statute regulating the content of                                                                           
 speech, we presume the statute is unconstitutional, and subject the statute                                                                           
 to strict scrutiny.  Collier v. City of Tacoma, 121 Wn.2d 737, 748-49, 854                                                                            
 P.2d 1046 (1993).
 
 B.   Constitutionality of RCW 42.17.530 
 
      The majority cites only a small portion of the challenged statute,                                                                               
 Majority op. at 7, and undertakes no analysis of the wording of the                                                                                   
 statute.  Thus, one must guess as to the constitutional infirmities the                                                                               
 majority claims exist.  The majority tells us the State may not prohibit                                                                              
 "unpalatable" speech.  Majority op. at 10.  But the statute addresses only                                                                            
 lies, not vitriol.  The majority tells us the State may not silence                                                                                   
 criticism of the government.  Id.  But the statute addresses only                                                                                     
 calculated falsehoods, not censure.  The majority tells us the State may                                                                              
 not chill uninhibited political debate.  Majority op. at 11.  But the                                                                                 
 statute addresses only malicious prevarication, not honest, robust,                                                                                   
 political debate.  The majority tells us factual blunders are best                                                                                    
 corrected by the opponent.  Majority op. at 12.  But the statute addresses                                                                            
 deliberate falsehoods, not innocent errors of fact.1
 
      The key to the majority's analysis of the statute is found in the                                                                                
 following two sentences:  "The State asserts it may prohibit false                                                                                    
 statements of fact contained in political advertisements.  The claim                                                                                  
 presupposes the State possesses an independent right to determine truth or                                                                            
 falsity in political debate."  Majority op. at 9.  The majority thus                                                                                  
 presumes the people of Washington have no authority to require persons to                                                                             
 tell the truth.  This presumption is, of course, wrong.  Perjury has been a                                                                           
 part of Washington's criminal code since territorial days.  See Ch. 9A.72                                                                             
 RCW.  Prohibitions against lying and bearing false witness may be found in                                                                            
 cultures worldwide from time immemorial.  See Richard H. Underwood, False                                                                             
 Witness:  A Lawyer's History of the Law of Perjury, 10 Ariz. J. Int'l &                                                                               
 Comp. L. 215 (1993), for a comprehensive survey of prohibitions against                                                                               
 lying.
 
      Although perjury itself concerns lying under oath or in official                                                                                 
 proceedings, there is no reason the State may not prohibit lying in other                                                                             
 contexts pursuant to the exercise of its police power.  That is precisely                                                                             
 what the State has done by enacting the challenged statute in this case. 
 
      The challenged statute is plainly a valid exercise of the police                                                                                 
 power.  Lawton v. Steele, 152 U.S. 133, 137 14 S. Ct. 499, 38 L. Ed. 385                                                                              
 (1894); State v. Crediford, 130 Wn.2d 747, 752, 927 P.2d 1129 (1996)                                                                                  
 (quoting State v. Brayman, 110 Wn.2d 183, 193, 751 P.2d 294 (1988), which                                                                             
 in turn quoted State v. Conifer Enters., Inc., 82 Wn.2d 94, 96-97, 508 P.2d                                                                           
 149 (1973)).  If the elected representatives of the people of Washington,                                                                             
 who are accountable to their constituents every two and four years, in                                                                                
 their considered judgment believe calculated lying does not belong in                                                                                 
 electoral politics, it is not for us to question the wisdom of or necessity                                                                           
 for such legislation.
 
      Turning to the First Amendment, the threshold question is whether the                                                                            
 statute affects speech over which the First Amendment affords protection.                                                                             
 Without examining the wording or effect of the statute, the majority simply                                                                           
 assumes protected speech is involved.  Subsuming the answer in the question                                                                           
 falls a good way short of the penetrating rigor a legitimate constitutional                                                                           
 analysis requires.  We start with the wording of the statute.
 
      Before 1988, RCW 42.17.530 read:
 	 
           A person shall not sponsor political advertising which                                                                                      
      contains information that the person knows, or should reasonably                                                                                 
      be expected to know, to be false.  No political advertising may                                                                                  
      falsely represent that a candidate is an incumbent for the office                                                                                
      sought.  A person or candidate shall not make, either directly or                                                                                
      indirectly, a false claim stating or implying the support or                                                                                     
      endorsement of any person or organization.                                                                                                       
                                                                                                                                                       
 In Laws of 1988, ch. 199, sec. 2, the Legislature replaced that language                                                                              
 with the following: 
 
           (1)  It is a violation of this chapter for a person to                                                                                      
      sponsor with actual malice:                                                                                                                      
           (a)  Political advertising that contains a false statement                                                                                  
      of material fact;                                                                                                                                
           (b)  Political advertising that falsely represents that a                                                                                   
      candidate is the incumbent for the office sought when in fact the                                                                                
      candidate is not the incumbent;                                                                                                                  
           (c)  Political advertising that makes either directly or                                                                                    
      indirectly, a false claim stating or implying the support or                                                                                     
      endorsement of any person or organization when in fact the                                                                                       
      candidate does not have such support or endorsement.                                                                                             
           (2)  Any violation of this section shall be proven by clear                                                                                 
      and convincing evidence.                                                                                                                         
                                                                                                                                                       
 The new statute now requires actual malice before a violation may be found.                                                                           
 In Laws of 1988, ch. 199, sec. 1, now codified as RCW 42.17.505(1), the                                                                               
 Legislature defined actual malice to mean "to act with knowledge of falsity                                                                           
 or with reckless disregard as to truth or falsity."  By requiring the                                                                                 
 intermediate standard of proof, clear and convincing evidence, the new                                                                                
 statute made violations more difficult to prove.  Thus, a person violates                                                                             
 the statute if and only if he or she sponsors political advertising that is                                                                           
 (1) a false statement of material fact (2) with actual malice, as defined,                                                                            
 and (3) is found to have done so by clear and convincing evidence.  One                                                                               
 example of a violation of this statute might be a political flyer from a                                                                              
 candidate who declares herself to be the incumbent when in fact she is not.                                                                           
 She has acted with "knowledge of falsity."2  Another example could be one                                                                             
 candidate's accusing an opponent of having been convicted of desertion                                                                                
 during the Vietnam War.  In a case such as this, the accuser may have no                                                                              
 actual knowledge one way or the other, but has violated the statute by                                                                                
 acting with "reckless disregard as to the truth or falsity" of the                                                                                    
 accusation.  These examples are what men and women of common understanding                                                                            
 would describe as deliberate lies.  Do deliberate lies come under the                                                                                 
 protective umbrella of the First Amendment?  The majority opinion says                                                                                
 "yes."  The Supreme Court of the United States has said "no" on numerous                                                                              
 occasions, as have all other courts addressing the same question. 
 
      The Supreme Court has unequivocally and repeatedly refused to extend                                                                             
 First Amendment protection to deliberate lies.  The Court said in Garrison                                                                            
 v. Louisiana, 379 U.S. 64, 75, 85 S. Ct. 209, 13 L. Ed. 2d 125 (1964): 
 
           The use of calculated falsehood, however, would put a                                                                                       
      different cast on the constitutional question.  Although honest                                                                                  
      utterance, even if inaccurate, may further the fruitful exercise                                                                                 
      of the right of free speech, it does not follow that the lie,                                                                                    
      knowingly and deliberately published about a public official,                                                                                    
      should enjoy a like immunity.  At the time the First Amendment                                                                                   
      was adopted, as today, there were those unscrupulous enough and                                                                                  
      skillful enough to use the deliberate or reckless falsehood as an                                                                                
      effective political tool to unseat the public servant or even                                                                                    
      topple an administration. Cf. Riesman, Democracy and Defamation:                                                                                 
      Fair Game and Fair Comment I, 42 Col. L. Rev. 1085, 1088-1111                                                                                    
      (1942).  That speech is used as a tool for political ends does                                                                                   
      not automatically bring it under the protective mantle of the                                                                                    
      Constitution.  For the use of the known lie as a tool is at once                                                                                 
      at odds with the premises of democratic government and with the                                                                                  
      orderly manner in which economic, social, or political change is                                                                                 
      to be effected.  Calculated falsehood falls into that class of                                                                                   
      utterances which "are no essential part of any exposition of                                                                                     
      ideas, and are of such slight social value as a step to truth                                                                                    
      that any benefit that may be derived from them is clearly                                                                                        
      outweighed by the social interest in order and morality. . . ."                                                                                  
      Chaplinsky v. New Hampshire, 315 U. S. 568, 572{, 62 S. Ct. 766,                                                                                 
      769, 86 L. Ed. 1031 (1942)}.  Hence the knowingly false statement                                                                                
      and the false statement made with reckless disregard of the                                                                                      
      truth, do not enjoy constitutional protection.                                                                                                   
                                                                                                                                                       
 These were the words of Justice Brennan, certainly not one disposed to                                                                                
 limit First Amendment freedoms. 
 
      Ten years later, in Gertz v. Robert Welch, Inc., 418 U.S. 323, 340, 94                                                                           
 S. Ct. 2997, 41 L. Ed. 2d 789 (1974), the Court reiterated:  "But there is                                                                            
 no constitutional value in false statements of fact.  Neither the                                                                                     
 intentional lie nor the careless error materially advances society's                                                                                  
 interest in `uninhibited, robust, and wide-open' debate on public issues,"                                                                            
 citing New York Times, 376 U.S. at 270.  And, in Brown v. Hartlage, 456                                                                               
 U.S. 45, 59, 102 S. Ct. 1523, 71 L. Ed. 2d 732 (1982), the Court said, "Of                                                                            
 course, demonstrable falsehoods are not protected by the First Amendment in                                                                           
 the same manner as truthful statements."  Accord Herbert v. Lando, 441 U.S.                                                                           
 153, 171, 99 S. Ct. 1635, 60 L. Ed. 2d 115 (1979) ("Spreading false                                                                                   
 information in and of itself carries no First Amendment credentials."),                                                                               
 cited with approval by Bill Johnson's Restaurants, Inc. v. National Labor                                                                             
 Relations Bd., 461 U.S. 731, 743, 103 S. Ct. 2161, 76 L. Ed. 2d 277 (1983)                                                                            
 ("false statements are not immunized by the First Amendment right to                                                                                  
 freedom of speech"); Rosenbloom v. Metromedia, Inc., 403 U.S. 29, 52, 91 S.                                                                           
 Ct. 1811, 29 L. Ed. 2d 296 (1971) ("Calculated falsehood, of course, falls                                                                            
 outside `the fruitful exercise of the right of free speech,' " citing                                                                                 
 Garrison, 379 U.S. at 75); Time, Inc. v. Hill, 385 U.S. 374, 389-90, 87 S.                                                                            
 Ct. 534, 17 L. Ed. 2d 456 (1967) ("But the constitutional guarantees can                                                                              
 tolerate sanctions against calculated falsehood without significant                                                                                   
 impairment of their essential function.  We held in New York Times that                                                                               
 calculated falsehood enjoyed no immunity in the case of alleged defamation                                                                            
 of a public official concerning his official conduct."); St. Amant v.                                                                                 
 Thompson, 390 U.S. 727, 732, 88 S. Ct. 1323, 20 L. Ed. 2d 262 (1968)                                                                                  
 ("Neither lies nor false communications serve the ends of the First                                                                                   
 Amendment."); Linn v. United Plant Guard Workers of Am., Local 114, 383                                                                               
 U.S. 53, 63, 86 S. Ct. 657, 15 L. Ed. 2d 582 (1966) ("{T}he most repulsive                                                                            
 speech enjoys immunity provided it falls short of a deliberate or reckless                                                                            
 untruth."); Vanasco v. Schwartz, 401 F. Supp. 87, 93 (S.D. N.Y. 1975)                                                                                 
 ("{W}e can agree with the Board's argument that calculated falsehoods are                                                                             
 of such slight social value that no matter what the context in which they                                                                             
 are made, they are not constitutionally protected."), aff'd, 423 U.S. 1041,                                                                           
 96 S. Ct. 763, 46 L. Ed. 2d 630 (1976).  See also Riley v. National Fed'n                                                                             
 of the Blind of North Carolina, Inc., 487 U.S. 781, 803, 108 S. Ct. 2667,                                                                             
 101 L. Ed. 2d 669 (1988) (Scalia, J., concurring in part, concurring in                                                                               
 judgment) ("Where core First Amendment speech is at issue, the State can                                                                              
 assess liability for specific instances of deliberate deception."); Ocala                                                                             
 Star-Banner Co. v. Damron, 401 U.S. 295, 301, 91 S. Ct. 632, 28 L. Ed. 2d                                                                             
 57 (1971) (White, J., concurring) ("Misinformation has no merit in itself;                                                                            
 standing alone it is as antithetical to the purposes of the First Amendment                                                                           
 as the calculated lie.").
 
      We have been no less vociferous in denouncing the calculated lie in                                                                              
 the campaign context: 
 
      {W}e do not believe that the First Amendment protects one who                                                                                    
      utters a statement with knowledge of its falsity, even in the                                                                                    
      context of a judicial campaign.  Such speech is not beneficial to                                                                                
      the public and is generally harmful to the person against whom it                                                                                
      is directed.  The only beneficiary of the comment is the utterer                                                                                 
      thereof.  On balance, such statements are not deserving of                                                                                       
      constitutional protection.                                                                                                                       
                                                                                                                                                       
 In re Donohoe, 90 Wn.2d 173, 181, 580 P.2d 1093 (1978).  We have not                                                                                  
 overruled this case by amending the Code of Judicial Conduct, as the                                                                                  
 majority asserts.  Majority op. at 16-17.  Nevertheless, the majority's                                                                               
 analysis calls into question the analysis of our own canons of judicial                                                                               
 conduct.  In Donohoe, a candidate for a judicial office deliberately                                                                                  
 altered campaign letters sent on behalf of her opponent in a fashion this                                                                             
 Court described as "reprehensible and a fraud upon the voting public."                                                                                
 Donohoe, 90 Wn.2d at 184.
 
      Likewise, in In re Kaiser, 111 Wn.2d 275, 759 P.2d 392 (1988), a                                                                                 
 judicial candidate suggested his opponent's support came from "drunk                                                                                  
 driving defense attorneys" and this Court found such statements were false.                                                                           
 In Kaiser, we specifically noted that political candidates, including                                                                                 
 judicial candidates, have rights of free speech, notwithstanding their                                                                                
 participation in the judicial campaign process.  But we also said, "We                                                                                
 issued two reprimands in Donohoe, however, because we recognized that free                                                                            
 speech guaranties do not extend far enough to protect falsehood."  Kaiser,                                                                            
 111 Wn.2d at 284.
 
      Other state courts have agreed with our prior holdings:  Fellows v.                                                                              
 National Enquirer, Inc., 211 Cal. Rptr. 809, 824 (Cal. App. 1985) ("{A}                                                                               
 publisher of what the Supreme Court has termed a `calculated falsehood' . .                                                                           
 . enjoys no constitutional protection."  (Citations omitted)), rev'd on                                                                               
 other grounds, 42 Cal. 3d 234, 721 P.2d 97, 228 Cal. Rptr. 215, 57                                                                                    
 A.L.R.4th 223 (1986); Long v. State, 622 So. 2d 536, 537 (Fla. App. ) ("The                                                                           
 use of calculated falsehoods under any circumstances, even in the criticism                                                                           
 of public officials, is not constitutionally protected."), review denied,                                                                             
 629 So. 2d 133 (Fla. 1993); Thibadeau v. Crane, 131 Ga. App. 591, 206                                                                                 
 S.E.2d 609, 610 (1974) ("There is no privilege protecting the use of                                                                                  
 calculated falsehood."); People v. Duryea, 76 Misc. 2d 948, 351 N.Y.S.2d                                                                              
 978, 988 (N.Y. Sup. Ct. 1974) ("Calculated falsehood is never protected by                                                                            
 the First Amendment."); People v. Bloss, 27 Mich. App. 687, 184 N.W.2d 299,                                                                           
 311 (1970) ("We see no difference constitutionally between the calculated                                                                             
 falsehood and the calculated appeal to prurient interest.  Neither is a                                                                               
 communication of ideas entitled to constitutional protection."), rev'd on                                                                             
 other grounds, 388 Mich. 409, 201 N.W.2d 806 (1972); Theckston v. Triangle                                                                            
 Publications Inc., 100 N.J. Super. 452, 242 A.2d 629, 631 ("Speech                                                                                    
 concerning public affairs is the essence of self-government so that, where                                                                            
 public officials are concerned, it is only the calculated falsehood which                                                                             
 will afford redress."), cert. denied, 393 U.S. 1001, 89 S. Ct. 486, 21 L.                                                                             
 Ed. 2d 466 (1968); State v. Powell, 114 N.M. 395, 839 P.2d 139, 142 (1992)                                                                            
 ("{T}he knowingly false statement and the false statement made with                                                                                   
 reckless disregard of the truth, do not enjoy constitutional protection.").
 
      Despite the mountain of United States Supreme Court and state court                                                                              
 authority to the contrary, the majority decides the First Amendment                                                                                   
 condones deliberate falsehoods in campaigns.  As support for its position,                                                                            
 the majority cites to New York Times Co. v. Sullivan, 376 U.S. 254, 84 S.                                                                             
 Ct. 710, 11 L. Ed. 2d 686, 95 A.L.R.2d 1412 (1964), on four separate                                                                                  
 occasions.  Yet nowhere does the majority opinion reveal the holding of New                                                                           
 York Times, which is "a public official cannot recover for defamation                                                                                 
 unless he or she establishes the defendant made the defamatory statement                                                                              
 with actual malice, that is, knowledge of its falsity or with reckless                                                                                
 disregard for whether it was false or not."  Richmond v. Thompson, 130                                                                                
 Wn.2d 368, 376, 922 P.2d 1343 (1996).  The new RCW 42.17.530(1)(a), having                                                                            
 added actual malice as a required element of the violation and having                                                                                 
 adopted from New York Times the exact language defining "actual malice,"                                                                              
 plainly passes muster under that case.  Similarly, the new statute's                                                                                  
 requirement of clear and convincing evidence mirrors the requirement for                                                                              
 the higher standard of proof set forth in Gertz v. Robert Welch, Inc., 418                                                                            
 U.S. 323, 342, 94 S. Ct. 2997, 41 L. Ed. 2d 789 (1974).  How, then, can a                                                                             
 statute on all fours with controlling United States Supreme Court authority                                                                           
 be unconstitutional in Washington?  As long as New York Times remains the                                                                             
 supreme law of the land, we are not free to ignore it, or to interpret it                                                                             
 to our liking, short of articulating independent state grounds for doing so                                                                           
 under the Washington constitution.  Nobody has made such an argument in                                                                               
 this case.  The United States Supreme Court would not find RCW                                                                                        
 42.17.530(1)(a) unconstitutional under its First Amendment jurisprudence.                                                                             
 Nor may we.  See Wash. Const. art I, sec. 2 ("The Constitution of the                                                                                 
 United States is the supreme law of the land.").
 
      The Court's holding in New York Times and its repeated refusals to                                                                               
 grant First Amendment protection to lies are completely dispositive of the                                                                            
 issues in this case.  The majority is undeterred by authority, however, and                                                                           
 finding no case extending First Amendment protection to deliberate lies in                                                                            
 political campaigns, asserts a novel proposition to support its conclusion:                                                                           
 the majority decides that everything the Supreme Court said in New York                                                                               
 Times, Garrison, and Gertz concerning deliberate lies is applicable only to                                                                           
 de