This court document can also be found at http://www.wa.gov/~COURTS/opinions/635340_D07.txt
                    Supreme Court of the State of Washington                                                                                          
                                                                                                                                                      
                            Opinion Information Sheet                                                                                                 
                                                                                                                                                      
Docket Number:       63534-0                                                                                                                          
Title of Case:       Ralph Seeley                                                                                                                     
                     v.                                                                                                                               
                     State of Washington                                                                                                              
File Date:           07/24/97                                                                                                                         
Oral Argument Date:  09/25/96                                                                                                                         
                                                                                                                                                      
                                                                                                                                                      
                                SOURCE OF APPEAL                                                                                                      
                                ----------------                                                                                                      
Appeal from Superior Court of Pierce County                                                                                                           
Docket No:      94-2-11862-1                                                                                                                          
Judgment or order under review                                                                                                                        
Date filed:     11/13/95                                                                                                                              
Judge signing:  Hon. Rosanne N. Buckner                                                                                                               
                                                                                                                                                      
                                                                                                                                                      
                                    JUSTICES                                                                                                          
                                    --------                                                                                                          
Authored by Barbara A. Madsen                                                                                                                         
Concurring: Barbara Durham                                                                                                                            
            James M. Dolliver                                                                                                                         
            Charles Z. Smith                                                                                                                          
            Richard P. Guy                                                                                                                            
            Charles W. Johnson                                                                                                                        
            Gerry L. Alexander                                                                                                                        
            Philip A. Talmadge                                                                                                                        
Dissenting: Richard B. Sanders                                                                                                                        
                                                                                                                                                      
                                                                                                                                                      
                                COUNSEL OF RECORD                                                                                                     
                                -----------------                                                                                                     
Counsel for Appellant(s)                                                                                                                              
            Melissa A. Cain                                                                                                                           
            Assistant Attorney General                                                                                                                
            905 Plum St                                                                                                                               
            PO Box 40109                                                                                                                              
            Olympia, WA  98504-0109                                                                                                                   
                                                                                                                                                      
Counsel for Respondent(s)                                                                                                                             
            Ralph Seeley                                                                                                                              
            Attorney At Law                                                                                                                           
            252 Broadway                                                                                                                              
            Tacoma, WA  98402                                                                                                                         
                                                                                                                                                      
Amicus Curiae on behalf of American Civil Liberties Union                                                                                             
            Kevin J. Hamilton                                                                                                                         
            40th Fl                                                                                                                                   
            1201 3rd Ave                                                                                                                              
            Seattle, WA  98101-3099                                                                                                                   
                                                                                                                                                      
            Erika J. Starrs                                                                                                                           
            4oth Floor                                                                                                                                
            1201 Third Ave                                                                                                                            
            Seattle, WA  98101                                                                                                                        
                                                                                                                                                      
            Stephen C. Willey                                                                                                                         
            Perkins Coie                                                                                                                              
            1201 3rd Ave Ste 4000                                                                                                                     
            Seattle, WA  98101-3099                                                                                                                   
                                                                                                                                                      
Amicus Curiae on behalf of Drug Policy Foundation of Washington                                                                                       
            Bruce Edward H. Johnson                                                                                                                   
            Davis Wright Tremaine                                                                                                                     
            2600 Century Square                                                                                                                       
            1501 4th Ave.                                                                                                                             
            Seattle, WA  98101-1688                                                                                                                   
                                                                                                                                                      
            Jeffrey T. Haley                                                                                                                          
            Suite 2460                                                                                                                                
            777 108th Avenue                                                                                                                          
            Bellevue, WA  98004-5117                                                                                                                  
                                                                                                                                                      
            Gregory J. Kopta                                                                                                                          
            Davis Wright Tremaine                                                                                                                     
            2600 Century Sq                                                                                                                           
            1501 4th Ave                                                                                                                              
            Seattle, WA  98101-1662                                                                                                                   
                                                                                                                                                      
            Kraig L. Baker                                                                                                                            
            2600 Century Square                                                                                                                       
            1501 4th Ave                                                                                                                              
            Seattle, WA  98101-1688                                                                                                                   
                                                                                                                                                      
Amicus Curiae on behalf of Drug Policy Foundation                                                                                                     
            Bruce Edward H. Johnson                                                                                                                   
            Davis Wright Tremaine                                                                                                                     
            2600 Century Square                                                                                                                       
            1501 4th Ave.                                                                                                                             
            Seattle, WA  98101-1688                                                                                                                   
                                                                                                                                                      
            Jeffrey T. Haley                                                                                                                          
            Suite 2460                                                                                                                                
            777 108th Avenue                                                                                                                          
            Bellevue, WA  98004-5117                                                                                                                  
                                                                                                                                                      
            Gregory J. Kopta                                                                                                                          
            Davis Wright Tremaine                                                                                                                     
            2600 Century Sq                                                                                                                           
            1501 4th Ave                                                                                                                              
            Seattle, WA  98101-1662                                                                                                                   
                                                                                                                                                      
            Kraig L. Baker                                                                                                                            
            2600 Century Square                                                                                                                       
            1501 4th Ave                                                                                                                              
            Seattle, WA  98101-1688                                                                                                                   
                                                                                                                                                      
Amicus Curiae on behalf of National Organization for the Reform                                                                                       
            Jeffrey Steinborn                                                                                                                         
            Steinborn & Associates                                                                                                                    
            3000 Smith Tower                                                                                                                          
            506 Second Avenue                                                                                                                         
            Seattle, WA  98104-2311                                                                                                                   
                                                                                                                                                      
            Michael D. Cutler                                                                                                                         
            Lawson & Weitzen                                                                                                                          
            425 Summer St 5th Floor                                                                                                                   
            Boston, MA  02210-1736                                                                                                                    
                                                                                                                                                      
                                                                                                                                                      
 Seeley v. State                                                                                                                                      
Majority by Madsen, J.                                                                                                                                
Dissent by Sanders, J.                                                                                                                                
                                                                                                                                                      
No. 63534-0                                                                                                                                           
                                                                                                                                                      
     Sanders, J. (dissenting)                                                                                                                         
     "When our rulers worry about our health, we should worry about                                                                                   
     our liberty."{1}                                                                                                                                 
                                                                                                                                                      
     The trial court, and the majority here, analyze Mr. Seeley's claim                                                                               
under the privileges and immunities clause of article I, section 12, of the                                                                           
Washington Constitution2 as well as the equal protection clause of the                                                                                
Fourteenth Amendment to the United States Constitution.3  Notwithstanding,                                                                            
I prefer the due process clause of the Fourteenth Amendment, as argued by                                                                             
amicus American Civil Liberties Union of Washington Foundation because the                                                                            
problem is how the government treats Mr. Seeley, not that Mr. Seeley is                                                                               
treated differently from others.4  Equalizing injustice does not cure it.                                                                             
I dissent.                                                                                                                                            
     This dissent relies primarily on recent Supreme Court precedent in two                                                                           
     abortion cases, Roe v. Wade, 410 U.S. 113, 93 S. Ct. 705, 35 L. Ed. 2d 147                                                                       
(1973) and Planned Parenthood v. Casey, 505 U.S. 833, 851, 112 S. Ct. 2791,                                                                           
120 L. Ed. 2d 674 (1992), wherein the Supreme Court majority credited the                                                                             
state's interest to preserve the life of the fetus as "important" but                                                                                 
nevertheless insufficient to prohibit the practice when measured against                                                                              
the liberty interests of the mother.  The majority cannot distinguish these                                                                           
cases.  If the state cannot prohibit abortions consistent with due process,                                                                           
it can hardly constitutionally prohibit drug use as its interest to do so                                                                             
is arguably much less important.  I further rely on Ravin v. State, 537                                                                               
P.2d 494 (Alaska 1975) which construes a comparable provision in the Alaska                                                                           
constitution to immunize persons who smoke marijuana in the privacy of                                                                                
their home from criminal prosecutions, as well as Washington v. Glucksberg,                                                                           
No. 96-110, 1997 WL 348094 and 355983 (U.S. June 26, 1997) which rejects                                                                              
the claim that due process protects the asserted right of physician                                                                                   
assisted suicide however still provides much comfort to Mr. Seeley, who                                                                               
claims due process protection against "arbitrary impositions and                                                                                      
purposeless restraints."5                                                                                                                             
     While the majority identifies Mr. Seeley as presenting his case pro se                                                                           
this dissent notes for the record Mr. Seeley is a most able attorney as                                                                               
well.  On this occasion he comes to court on his own behalf to argue a                                                                                
matter of a very personal nature directly pertaining to physical pain which                                                                           
only he can experience.  By contrast considerations of public need and                                                                                
necessity are at most lawyer-like abstractions.  Refusing palliative relief                                                                           
to a dying man may please the politicians yet does great damage to Seeley's                                                                           
liberty and nothing for his health.                                                                                                                   
     As to Mr. Seeley's claim that inhalation of leaf form marijuana                                                                                  
subsequent to chemotherapy relieves symptoms of nausea, the State admitted                                                                            
during oral argument it "cannot dispute Mr. Seeley's beliefs about                                                                                    
marijuana and how it affects him . . . ."  Oral Argument Tape (Sept. 25,                                                                              
1996).  Seeley's medical doctor filed an affidavit attesting that in his                                                                              
medical judgment Mr. Seeley would benefit from the use of marijuana.6                                                                                 
     But the State purports to justify this total prohibition of marijuana                                                                            
by taking a "larger focus."  It asserts absolute criminal prohibition, even                                                                           
as applied to Mr. Seeley, promotes legitimate governmental objectives                                                                                 
associated with discouraging drug abuse and otherwise protecting the                                                                                  
citizenry from itself by curtailing what it alleges to be the unknown                                                                                 
consequences associated with the inhalation of marijuana.  But these                                                                                  
reasons even if valid have no particular application to Seeley who is                                                                                 
terminally ill, admittedly finds relief in smoking marijuana, and seeks to                                                                            
follow the advice of his own physician who attests marijuana is medically                                                                             
advisable.  From the perspective of one writhing in nausea on the tiled                                                                               
floor of an oncological recovery room, the State's justifications to                                                                                  
withhold the blessings of relief are more sophomoric than substantive.7                                                                               
     The text of the Fourteenth Amendment's due process clause mandates no                                                                            
state shall "deprive any person of life, liberty, or property, without due                                                                            
process of law."  The clause views the matter from the individual's                                                                                   
perspective, not the State's, as it poses the rule in terms of "any person"                                                                           
who might suffer the deprivation.8  Its remedy is simple, and absolute:                                                                               
prohibit the deprivation absent that process which is due.                                                                                            
     That the process due extends beyond matters of mere procedure is                                                                                 
thoroughly settled.  Justice Brandeis explained 70 years ago, "{d}espite                                                                              
arguments to the contrary which had seemed to me persuasive, it is settled                                                                            
that the due process clause of the Fourteenth Amendment applies to matters                                                                            
of substantive law as well as to matters of procedure.  Thus all                                                                                      
fundamental rights comprised within the term liberty are protected by the                                                                             
federal Constitution from invasion by the states."  Whitney v. California,                                                                            
274 U.S. 357, 373, 47 S. Ct. 641, 647, 71 L. Ed. 1095 (1927) (Brandeis, J.,                                                                           
concurring).  See also Planned Parenthood v. Casey, 505 U.S. 833, 846, 851,                                                                           
112 S. Ct. 2791, 120 L. Ed. 2d 674 (1992) (while the clause appears to                                                                                
address procedure alone, the liberty protections referred to in the clause                                                                            
include a substantive component "`barring certain government actions                                                                                  
regardless of the fairness of the procedures used to implement them'")                                                                                
(quoting Daniels v. Williams, 474 U.S. 327, 331, 106 S. Ct. 662, 88 L. Ed.                                                                            
2d 662 (1986)).                                                                                                                                       
     It may also be reasonably stated, without fear of contradiction, that                                                                            
over the last century the clause has regained much of its vigor as a                                                                                  
substantive limitation on state power.  An early test for judicial                                                                                    
implementation of the clause is summarized in Lawton v. Steele, 152 U.S.                                                                              
133, 137, 14 S. Ct. 499, 501, 38 L. Ed. 385 (1894).  There the Supreme                                                                                
Court noted that a legislative "determination as to what is a proper                                                                                  
exercise of its police powers is not final or conclusive, but is subject to                                                                           
the supervision of the courts" (id. at 137) and emphasized the need to                                                                                
protect against governmental acts "involving an unnecessary invasion of { }                                                                           
rights" and infringement upon individual acts which are "harmless in                                                                                  
themselves, and which might be carried on without detriment to the public                                                                             
interests."  Id. at 138.                                                                                                                              
     To justify the state in . . . interposing its authority in behalf                                                                                
     of the public, it must appear First, that the interests of the                                                                                   
     public . . . require such interference; and, second, that the                                                                                    
     means are reasonably necessary for the accomplishment of the                                                                                     
     purpose, and not unduly oppressive upon individuals.                                                                                             
                                                                                                                                                      
Id. at 137.                                                                                                                                           
                                                                                                                                                      
     If the challenged governmental act fails any aspect of the test it is                                                                            
an invalid exercise of the police power and an unconstitutional "public                                                                               
encroachment upon private interests."  Goldblatt v. Town of Hempstead, 369                                                                            
U.S. 590, 594, 82 S. Ct. 987, 8 L. Ed. 2d 130 (1962) ("The classic                                                                                    
statement of the rule in Lawton v. Steele{ } is still valid today . . .                                                                               
.").                                                                                                                                                  
     The Washington Supreme Court has repeatedly followed Lawton.  See                                                                                
     State v. Brown, 37 Wash. 97, 101, 79 P. 635 (1905) (following Lawton this                                                                        
court struck down a state law requiring dental offices to be owned by                                                                                 
dentists on the ground such law was not necessary to further any valid                                                                                
state objective), overruled in part by State v. Boren, 36 Wn.2d 522, 219                                                                              
P.2d 566, (1950); City of Seattle v. Proctor, 183 Wash. 293, 298, 48 P.2d                                                                             
238 (1935) ("in order to sustain legislative interference with the business                                                                           
of the citizen, the court must be able to see that the act tends in some                                                                              
degree to promote the public health, morals, safety, or welfare.  In every                                                                            
case the means adopted must be reasonably necessary to accomplish that                                                                                
purpose, and should not be unduly oppressive upon the citizen.  The                                                                                   
determination of the Legislature as to these matters is not conclusive, but                                                                           
is subject to the supervision of the courts, and, if the above                                                                                        
prerequisites are wanting, a law imposing unreasonable restrictions on a                                                                              
lawful occupation will be held void."); Cougar Business Owners Ass'n v.                                                                               
State, 97 Wn.2d 466, 477, 647 P.2d 481 (1982) ("The classic statement of                                                                              
the rule in Lawton v. Steele{ }, is still valid today . . . ."), cert.                                                                                
denied, 459 U.S. 971, 103 S. Ct. 301, 74 L. Ed. 2d 283 (1982); Orion Corp.                                                                            
v. State, 109 Wn.2d 621, 646-47, 747 P.2d 1062 (1987) ("Under the classic,                                                                            
3-pronged, substantive due process test of reasonableness, a police power                                                                             
action must be reasonably necessary to serve a legitimate state                                                                                       
interest."), cert. denied, 486 U.S. 1022, 108 S. Ct. 1996, 100 L. Ed. 2d                                                                              
227 (1988); Sintra, Inc. v. City of Seattle, 119 Wn.2d 1, 829 P.2d 765                                                                                
($219,000 fee levied against an individual landowner violates substantive                                                                             
due process), cert. denied, 506 U.S. 1028, 113 S. Ct. 676, 121 L. Ed. 2d                                                                              
598 (1992); Guimont v. Clarke, 121 Wn.2d 586, 609, 854 P.2d 1 (1993) (law                                                                             
requiring landowner to pay $7,500 in relocation assistance for each tenant                                                                            
violates substantive due process under Lawton test), cert. denied, 510 U.S.                                                                           
1176, 114 S. Ct. 1216, 127 L. Ed. 2d 563 (1994); Rivett v. City of Tacoma,                                                                            
123 Wn.2d 573, 870 P.2d 299 (1994) (Tacoma ordinance requiring                                                                                        
indemnification for sidewalk injuries from abutting landowners violates                                                                               
substantive due process); Robinson v. City of Seattle, 119 Wn.2d 34, 830                                                                              
P.2d 318 (tenant relocation assistance payments unduly oppressed property                                                                             
owner under Lawton test), cert. denied, 506 U.S. 1028, 113 S. Ct. 676, 121                                                                            
L. Ed. 2d 598 (1992).                                                                                                                                 
     Lawton is particularly applicable here as Seeley asserts his use of                                                                              
medicinal marijuana to treat the symptoms of chemotherapy greatly benefits                                                                            
him while at the same time is "harmless in {itself}" and "might be carried                                                                            
on without detriment to the public interests."  Lawton, 152 U.S. at 138.                                                                              
Although in this jurisdiction many applications of the Lawton rule pertain                                                                            
to concerns associated with the ownership and use of real property, we                                                                                
should recall the classical formulation of such matters provides that a                                                                               
man's first and most fundamental property interest is in his person (James                                                                            
Madison, Essay on Property for the National Gazette (Mar. 27, 1792), in 14                                                                            
The Papers of James Madison 266-68 (Robert A. Rutland & Thomas A. Mason et                                                                            
al. eds., 1983)) (one's property interest extends not only to one's "land,                                                                            
or merchandise, or money" but also to "the safety and liberty of his                                                                                  
person. . . .").  And efforts to dichotomize interests of life, liberty,                                                                              
and property lack historical justification.  See Sinaloa Lake Owners Ass'n                                                                            
v. City of Simi Valley, 882 F.2d 1398, 1409 n.11 (9th Cir. 1989) ("Freedoms                                                                           
granted by the bill of rights were cut from a single constitutional cloth                                                                             
and {were} never dichotomized into personal and property.") (quoting Norman                                                                           
Karlin, Back to the Future:  From Nollan to Lochner, 17 Sw. U. L. Rev. 627,                                                                           
637-38 (1988)).                                                                                                                                       
     Although Planned Parenthood v. Casey, 505 U.S. 833, 876, 112 S. Ct.                                                                              
2791, 120 L. Ed. 2d 674 (1992) did not cite Lawton, its analysis proceeds                                                                             
on the same track:  do the interests of the public require such                                                                                       
interference?  I find the analysis in Casey as well as its antecedent, Roe                                                                            
v. Wade, 410 U.S. 113, 93 S. Ct. 705, 35 L. Ed. 2d 147 (1973) wholly                                                                                  
dispositive in Mr. Seeley's favor.                                                                                                                    
     Let us recall both Roe and Casey, like the case before us, focus upon                                                                            
an individual's claim that the State lacks sufficient justification to                                                                                
dictate to a woman matters associated with her bodily integrity, abortion                                                                             
specifically.  A majority in Roe recognized that the State "may properly                                                                              
assert important interests in safeguarding health, in maintaining medical                                                                             
standards, and in protecting potential life."  Roe, 410 U.S. at 154.                                                                                  
Similarly, a majority in Casey recognized these same legitimate interests,                                                                            
yet held "legitimate interests are not enough."  Casey, 505 U.S. at 932                                                                               
(Blackmun, J., concurring).                                                                                                                           
     As a general proposition I posit if the state's interest to regulate                                                                             
abortion in the context of Casey and Roe is insufficient, the State's                                                                                 
asserted interest to criminalize Mr. Seeley's ingestion of marijuana to                                                                               
ease the effects of nausea is even less so.                                                                                                           
     Casey begins with favorable reference to the second Justice Harlan's                                                                             
dissent in Poe v. Ullman, 367 U.S. 497, 543, 81 S. Ct. 1752, 6 L. Ed. 2d                                                                              
989 (1961) (Harlan, J., dissenting), which discusses the liberty referenced                                                                           
in the due process clause:  "This `liberty' is not a series of isolated                                                                               
points pricked out in terms of the taking of property, the freedom of                                                                                 
speech, press, and religion; the right to keep and bear arms; the freedom                                                                             
from unreasonable searches and seizures; and so on.  It is a rational                                                                                 
continuum which, broadly speaking, includes a freedom from all substantial                                                                            
arbitrary impositions and purposeless restraints."9  Thus the majority in                                                                             
Casey rejected the "rational relation" test upon which our majority hangs                                                                             
its hat.  Majority at 35 n.20.  Citing numerous examples, Casey focused                                                                               
directly on matters "involving the most intimate and personal choices . . .                                                                           
central to personal dignity and autonomy" which are "central to the liberty                                                                           
protected by the Fourteenth Amendment," 505 U.S. at 851, and then states:                                                                             
     At the heart of liberty is the right to define one's own concept                                                                                 
     of existence, of meaning, of the universe, and of the mystery of                                                                                 
     human life.  Beliefs about these matters could not define the                                                                                    
     attributes of personhood were they formed under compulsion of the                                                                                
     State.                                                                                                                                           
                                                                                                                                                      
Casey, 505 U.S. at 851.                                                                                                                               
     Apparently the Supreme Court opines personal choices essential to                                                                                
personal dignity and autonomy, even when those choices are at odds with                                                                               
legitimate state interests, are constitutionally privileged.  According to                                                                            
Casey, these considerations have application to abortion because natural                                                                              
childbirth involves "pain that only she must bear" as well as "suffering .                                                                            
. . intimate and personal . . . ."  Casey, 505 U.S. at 852.  The term                                                                                 
"personal" is repeated throughout the course of the opinion, which also                                                                               
characterizes Roe as an example of a rule "of personal autonomy and bodily                                                                            
integrity, with doctrinal affinity to cases recognizing limits on                                                                                     
governmental power to mandate medical treatment or to bar its rejection."                                                                             
     Casey, 505 U.S. at 857.  Turning aside a challenge to overrule Roe, Casey                                                                        
"decided that any regulation touching upon the abortion decision must                                                                                 
survive strict scrutiny, to be sustained only if drawn in narrow terms to                                                                             
further a compelling state interest."  Casey, 505 U.S. at 871.                                                                                        
     Were we to restrict Roe and Casey to a specific narrow holding on                                                                                
abortion we would rob these decisions of their claimed basis in the                                                                                   
fundamental principles inherent in substantive due process.  Scholars                                                                                 
(sometimes critically) argue the statements contained in Roe and Casey                                                                                
"apply to nonrights such as a person's desire to consume heroin, or not to                                                                            
wear a motorcycle helmet, as persuasively as they do to procreational                                                                                 
interests."  David Crump, How Do the Courts Really Discover Unenumerated                                                                              
Fundamental Rights?  Cataloguing the Methods of Judicial Alchemy, 19 Harv.                                                                            
J. L. & Pub. Pol. 795, 894 n.446 (1996).                                                                                                              
     I would apply the aforementioned analysis set forth in Lawton, Roe,                                                                              
and Casey to the facts at hand in the following manner.                                                                                               
Public v. Private Interests                                                                                                                           
     First, Lawton asks whether the public interest justifies such                                                                                    
interference with the individual.  Roe and Casey clarify that the more                                                                                
personal the individual interest, the more that interest concerns bodily                                                                              
autonomy, the more that interest centers on purely personal concerns such                                                                             
as the avoidance of pain through a medical procedure, the less likely the                                                                             
governmental restraint will be upheld.  The rationale behind Glucksberg is                                                                            
much the same.  An absolute criminal bar to the use of marijuana includes                                                                             
specifically personal concerns of bodily autonomy coupled with the personal                                                                           
desire to mitigate if not alleviate needless physical suffering.  These are                                                                           
grave interests which favor the individual.                                                                                                           
     On the other hand, the claimed interests of the State are                                                                                        
insubstantial.  There is little relation between the ingestion of marijuana                                                                           
by Mr. Seeley and the specter of drug abuse by others, other than the                                                                                 
desire to make a political statement that marijuana in leaf form has no                                                                               
legitimate use under any conceivable circumstance.10  But the government's                                                                            
     argument that the ingestion of marijuana may have uncertain medical                                                                              
consequences seems unpersuasive when, at the same time, the government                                                                                
concedes that it cannot dispute Mr. Seeley's testimony about how its                                                                                  
ingestion affects him, the tragic medical fact that he is terminally ill,                                                                             
nor the fact that Seeley's doctor states on the record it is in Seeley's                                                                              
interest to use marijuana for medical reasons.                                                                                                        
     To emphasize this is the necessary constitutional result I would also                                                                            
find Ravin v. State, 537 P.2d 494 (Alaska 1975) persuasive. Ravin                                                                                     
invalidated a similar Alaska statute insofar as it prohibited one from                                                                                
possessing and smoking marijuana in his own home.  Ravin identified                                                                                   
"unwanted governmental intrusions into one's privacy," 537 P.2d at 499, as                                                                            
well as the "right of personal autonomy in relation to choices affecting an                                                                           
individual's personal life."  Id. at 500.  Considering the recreational use                                                                           
of marijuana in one's home, a less compelling circumstance than what we                                                                               
have here, the court emphasized "{t}he experiences generated by use of                                                                                
marijuana are mental in nature . . . and thus among the most personal and                                                                             
private experiences possible.  So long as conduct does not produce                                                                                    
detrimental results, the right of privacy protects the individual's conduct                                                                           
designed to affect these inner areas of the personality. . . . and so the                                                                             
statute infringed on the right of personal autonomy."  Ravin, 537 P.2d at                                                                             
501.  The Alaska court also reflected upon the opinion of Justice T. G.                                                                               
Kavanagh in People v. Sinclair, 387 Mich. 91, 194 N.W.2d 878, 896 (1972)                                                                              
which recited "`Big brother' cannot, in the name of Public health, dictate                                                                            
to anyone what he can eat or drink or smoke in the Privacy of his own                                                                                 
home."  See also Suenram v. Society Valley Hosp., 155 N.J. Super. 593, 383                                                                            
A.2d 143 (1977) (recognizing constitutional privacy right of informed                                                                                 
cancer patient to take laetrile).                                                                                                                     
Necessary Means                                                                                                                                       
     Even assuming the interests of the public are sufficient to require                                                                              
such interference, Lawton further requires the means be reasonably                                                                                    
necessary to accomplish the purpose.  Lawton, 152 U.S. at 138.  But the                                                                               
means employed here, total and absolute prohibition, are anything but that.                                                                           
Under our statute marijuana in leaf form is not even available through                                                                                
medical prescription, unlike PCP angel dust, cocaine, opium, and morphine.11                                                                          
Our statute is an absolute prohibition against physician prescription, no                                                                             
matter what the learned medical judgment of our state-licensed                                                                                        
practitioner.  It forbids the physician to practice his healing arts and                                                                              
denies the patient benefit of professional care.12  Such is the situation                                                                             
notwithstanding the opinion widely held by physicians that medicinal                                                                                  
marijuana is safe and efficacious and should be used for a variety of                                                                                 
     ailments.  See Harvard Professor Lester Grinspoon, M.D. and James B.                                                                             
Bakalar, Marihuana, the Forbidden Medicine (1993).                                                                                                    
     A recent study conducted amongst the members of the Washington State                                                                             
Medical Association found 80 percent of its doctors favored controlled                                                                                
availability of marijuana for medical purposes.  CP at 561 (In the Matter                                                                             
of Marijuana Rescheduling Petition {Drug Enforcement Administration}                                                                                  
Opinion and Recommended Ruling, Findings of Fact, Conclusions of Law and                                                                              
Decision of Administrative Law Judge (Sept. 6, 1988) (Young Opinion)).                                                                                
Another recent study found that 44 percent of oncologists surveyed had                                                                                
already recommended the illegal use of marijuana to at least one patient                                                                              
and half would prescribe it to other patients if doing so was legal.  R.                                                                              
Doblin & M. A. R. Kleiman, Marijuana as Anti-emetic Medicine:  A Survey of                                                                            
Oncologists' Attitudes and Experiences, Journal of Clinical Oncology 9                                                                                
(1991) 1275-1280 n.292 (cited in Grinspoon & Bakalar, supra at 39).                                                                                   
Individuals anecdotally praise the successful use of medical marijuana for                                                                            
a variety of ailments.  California and Arizona voters recently approved                                                                               
physician prescription of marijuana in their states.  Derrick Augustus                                                                                
Carter, Knight in the Duel with Death:  Physician Assisted Suicide and the                                                                            
Medical Necessity Defense, 41 Vill. L. Rev. 663, 723 (1996).  The New                                                                                 
England Journal of Medicine, the premier authority in this country on                                                                                 
medical developments, editorialized in January 1997 against prohibition.                                                                              
Dr. Jerome Kassirer, editor, 336 New England Journal of Medicine 366                                                                                  
(1997).  After cataloging the medical benefits, the journal's editor opined                                                                           
government authorities are "out of step with the public" and the medical                                                                              
community and urged the government "to rescind their prohibition of the                                                                               
medical use of marijuana for seriously ill patients and allow physicians to                                                                           
decide which patients to treat."  Id.  The editorial concluded that                                                                                   
depriving seriously ill patients medical marijuana is "inhumane."  Id.                                                                                
     A well-known case documents how the government has approached the                                                                                
issue.  CP 533-603 (Young Opinion, supra at 533).  Pursuant to federal law                                                                            
the Drug Enforcement Agency must reclassify any schedule I drug if a                                                                                  
petitioner can demonstrate an accepted medical use.  In 1972 the National                                                                             
Organization for the Reform of Marijuana Laws (NORML) filed such a                                                                                    
petition.  Grinspoon & Bakalar, supra at 13.  Three times the agency                                                                                  
refused to process the petition and three times the federal circuit court                                                                             
ordered the agency to consider the petition on its merits.  Fourteen years                                                                            
later, in 1986, the DEA finally directed its administrative law judge to                                                                              
hear the case.  Judge Francis Young took evidence at various hearings for                                                                             
two years and issued a 68-page opinion in 1988.  Judge Young unambiguously                                                                            
recommended making marijuana medically available and concluded:                                                                                       
          The overwhelming preponderance of the evidence in this                                                                                      
     record establishes that marijuana has a currently accepted                                                                                       
     medical use in treatment in the United States for nausea and                                                                                     
     vomiting resulting from chemotherapy treatments in some cancer                                                                                   
     patients.  To conclude otherwise, on this record, would be                                                                                       
     unreasonable, arbitrary and capricious.                                                                                                          
                                                                                                                                                      
CP at 569; Young Opinion, supra at 34.                                                                                                                
     Notwithstanding Judge Young's thoroughly documented opinion, the head                                                                            
of the Drug Enforcement Agency denied the petition for rescheduling,                                                                                  
relying upon "common sense" that there is no medical use of marijuana.                                                                                
     I recite these facts as they are pertinent to the second prong of the                                                                            
Lawton test insofar as they all suggest availability of leaf marijuana by                                                                             
prescription as a means by which the government could accomplish some of                                                                              
its alleged objectives while making the substance available to those with a                                                                           
particular medical need; although I hasten to add availability only through                                                                           
prescription may not be sufficient to overcome objections raised under the                                                                            
first prong of the test.  Compare Ravin v. State, 537 P.2d 494 (Alaska                                                                                
1975) (home marijuana use for recreational as well as medical use                                                                                     
protected).                                                                                                                                           
Unduly Oppressive Upon Individuals                                                                                                                    
     The third prong of Lawton requires the result not be unduly oppressive                                                                           
upon individuals.  I find our criminal prohibition on marijuana unduly                                                                                
oppressive in every sense of the word.  Our court has previously                                                                                      
invalidated state and local legislative acts on precisely this ground in                                                                              
the context of rental housing relocation payments (Robinson v. City of                                                                                
Seattle), demolition fees (Sintra v. City of Seattle), and trailer park                                                                               
relocation fees (Guimont v. State).  This prong of the rule, consistently                                                                             
applied, would require no less in the case at bar.  I doubt many                                                                                      
individuals would require Mr. Seeley to suffer extreme nausea in lieu of                                                                              
the relief he could obtain from a marijuana cigarette.  But it seems the                                                                              
government is endowed with neither the compassion nor mercy possessed by                                                                              
the ordinary citizen.  However, insofar as the Fourteenth Amendment                                                                                   
prohibits the State from depriving anyone of their liberty absent due                                                                                 
process, it is the duty of the judicial branch of government to save and                                                                              
protect "any person," not the least of whom is Ralph Seeley, from bearing                                                                             
the unduly oppressive weight of government action upon his weakened                                                                                   
shoulders.                                                                                                                                            
Reply to Majority's Due Process Analysis                                                                                                              
     The majority's discussion of the due process clause is confined to but                                                                           
a single footnote.  Majority at 35 n.20.  Two propositions are there                                                                                  
tendered:  (1) due process is satisfied if a total prohibition of marijuana                                                                           
is "rationally related" to accomplishing a legitimate state interest and                                                                              
(2) a number of cases from other jurisdictions have held that such a                                                                                  
prohibition is indeed "rational."                                                                                                                     
a.  Rational Relationship Test Rejected                                                                                                               
     Apparently the majority opts for an extremely deferential standard                                                                               
whereby the law is upheld if the court can even imagine any hypothetical                                                                              
set of facts "presumed to exist" under which the Legislature might have                                                                               
constitutionally enacted the law.  See State's Brief in Response to Brief                                                                             
of ACLU at 8.  This test, however, has been inconsistently utilized by the                                                                            
United States Supreme Court, wherein it was abandoned in Casey, questioned                                                                            
in Glucksberg, obviously out of step with Lawton, and makes no sense in                                                                               
this case.                                                                                                                                            
     It is true the United States Supreme Court has sometimes applied such                                                                            
a two-tiered approach to due process claims.  If it labels the liberty                                                                                
interest at stake "fundamental" it opines the State cannot regulate same                                                                              
absent a narrowly tailored compelling state interest.  See Roe v. Wade, 410                                                                           
U.S. 113, 93 S. Ct. 705, 35 L. Ed. 2d 147 (1973).  If, on the other hand,                                                                             
the individual interest were found to be less than fundamental13 the state                                                                            
action will be upheld unless there is no imaginable rational basis to                                                                                 
support it.14  Compare, e.g., Bowers v. Hardwick, 478 U.S. 186, 196, 106 S.                                                                           
     Ct. 2841, 92 L. Ed. 2d 140 (1986) (popular view that homosexuality is                                                                            
immoral provides sufficient rational basis for anti-sodomy laws).                                                                                     
     But in reality simply labeling the interest has proven dispositive                                                                               
because strict scrutiny is virtually impossible to pass while rational                                                                                
basis is virtually impossible to fail.  Francis S. Chlapowski, The                                                                                    
Constitutional Protection of Informational Privacy, 71 B.U. L. Rev. 133,                                                                              
145 (1991) ("{W}hen the question of whether a right is fundamental is                                                                                 
raised, the preliminary finding of a `fundamental' interest is usually                                                                                
outcome-determinative.").  See Russell W. Galloway, Jr., Basic Substantive                                                                            
Due Process Analysis, 26 U.S.F. L. Rev. 625, 645 (1992) (rational basis "is                                                                           
so minimal" that "{t}he outcome is a foregone conclusion. . . .  The test                                                                             
involves `minimal scrutiny in theory and virtually none in fact.'")                                                                                   
(citation omitted); see also Laurence H. Tribe, American Constitutional Law                                                                           
343 (2d ed. 1988) (hereinafter Tribe, American Constitutional Law)                                                                                    
(referring to rational basis as imposing "relatively toothless limits" on                                                                             
the state).                                                                                                                                           
     This two-tiered classification system of strict scrutiny and rational                                                                            
basis has proven problematic and subject to criticism because it shoehorns                                                                            
what in reality exists on a continuum into absolute but artificial                                                                                    
categories.  Compare Casey, 505 U.S. at 851 (citing Poe, 367 U.S. at 543                                                                              
which analyzes "liberty interests upon "a rational continuum which, broadly                                                                           
speaking, includes a freedom from all substantive arbitrary impositions and                                                                           
purposeless restraints.").  While the 14th Amendment simply references                                                                                
"liberty," the question posed by the majority is whether there is a                                                                                   
"fundamental interest" to smoke marijuana.  I disagree with this                                                                                      
formulation because the constitution speaks of principles, not specifics.                                                                             
Freedom from needless suffering; the right to individual autonomy; the                                                                                
right to bodily integrity; the right to physician treatment and medical                                                                               
assistance; and freedom from arbitrary, privacy-invading restraints are the                                                                           
principles applicable here.                                                                                                                           
     Better we should question the predicate which supposedly justifies                                                                               
state intervention in the first place than shift the burden to the private                                                                            
citizen to show why he should be free which is, or should be, the natural                                                                             
state in a free society.  Compare Youngberg v. Romeo, 457 U.S. 307, 321,                                                                              
102 S. Ct. 2452, 73 L. Ed. 2d 28 (1982) ("Accordingly, whether respondent's                                                                           
constitutional rights have been violated must be determined by balancing                                                                              
his liberty interests against the relevant state interests."); Cruzan v.                                                                              
Director, Missouri Dept. of Health, 497 U.S. 261, 278-79, 110 S. Ct. 2841,                                                                            
111 L. Ed. 2d 224 (1990) (an individual's "liberty interests" must be                                                                                 
balanced against the state's interest in regulation); Foucha v. Louisiana,                                                                            
504 U.S. 71, 79-80, 112 S. Ct. 1780, 118 L. Ed. 2d 437 (1992) (balancing an                                                                           
individual's liberty interest in remaining free from bodily restraint                                                                                 
against the state's punitive interest in restraining him); and Glucksberg,                                                                            
1997 WL 348094, 355983 (U.S. June 26, 1997) (concurring opinions appear to                                                                            
embrace balancing test and reject rational relation test).  "The purpose of                                                                           
the Constitution and Bill of Rights, unlike more recent models promoting a                                                                            
welfare state, was to take government off the backs of people."  Schneider                                                                            
v. Smith, 390 U.S. 17, 25, 88 S. Ct. 682, 687, 19 L. Ed. 2d 799 (1968).15                                                                             
     Planned Parenthood v. Casey, 505 U.S. 833, 876, 112 S. Ct. 2791 (1992)                                                                           
     held the balancing approach was superior to the two-tiered approach because                                                                      
the "liberty" protected by the Fourteenth Amendment must be viewed on a                                                                               
continuum which balances the citizen's need for freedom of action against                                                                             
the state's justification for intervention.  Lawton is much the same since                                                                            
under the first prong of Lawton the court must determine "the interests of                                                                            
the public {that} . . . require such interference."  Lawton, 152 U.S. at                                                                              
137.                                                                                                                                                  
     Properly viewed, under the rational continuum test, Seeley prevails                                                                              
because his need is personal and great, whereas the state's interest to                                                                               
prevent the conduct is small if not pretextual.                                                                                                       
     Even were we to adhere to the majority's two-tiered approach, I would                                                                            
nevertheless reject the majority's claim that Seeley's interest to inhale                                                                             
or ingest any substance to relieve his agony is in any degree less                                                                                    
fundamental than any other interest judicially recognized as such.16                                                                                  
Offensive, in the extreme, is the proposition that the government may                                                                                 
restrict ingestion of a substance found by a licensed physician to be                                                                                 
medically advisable to comfort a terminal patient.  Such right is as                                                                                  
fundamental as any.  Compare, e.g., Cruzan (fundamental right to refuse                                                                               
life support by exercising personal control of medical treatment).                                                                                    
     Washington v. Harold Glucksberg, No. 96-110, 1997 WL 348094 and 355983                                                                           
(U.S. June 26, 1997) also supports this view.  While Glucksberg unanimously                                                                           
rejected a claimed constitutional right to physician assisted suicide                                                                                 
because of the overriding state interest to preserve human life, no single                                                                            
opinion represented an unqualified majority.  Justice O'Connor, and several                                                                           
other justices comprising a majority of five, wrote separately to emphasize                                                                           
their concurrence was conditioned upon the existence of laws insuring that                                                                            
terminal patients may access pain relief.  See Glucksberg, 1997 WL 355983                                                                             
at *1 (O'Connor, J., concurring) ("{A} patient who is suffering from a                                                                                
terminal illness and who is experiencing great pain has no legal barriers                                                                             
to obtaining medication, from qualified physicians, to alleviate that                                                                                 
suffering, even to the point of causing unconsciousness and hastening                                                                                 
death.").  Similarly, Justice Breyer, also concurring in result, wrote,                                                                               
"Were the legal circumstances different for example, were state law to                                                                                
prevent the provision of palliative care, including the administration of                                                                             
drugs as needed to avoid pain at the end of life then the law's impact upon                                                                           
serious and otherwise unavoidable physical pain . . . would be more                                                                                   
directly at issue.  And as Justice O'Connor suggests, the Court might have                                                                            
to revisit its conclusions in these cases."  Id. at *11 (Breyer, J.,                                                                                  
concurring).  Unlike the unsuccessful physicians in Glucksberg, Seeley is                                                                             
incapacitated by nausea precisely because he seeks to save his own life.                                                                              
Yet the State, and the majority of this court, would slap from his hand                                                                               
exactly that which Seeley, his physician, and even the State acknowledge                                                                              
will improve the quality of his life to the detriment of no one.  Compare                                                                             
Glucksberg, WL 355983 at *5 (Stevens, J., concurring) ("Avoiding                                                                                      
intolerable pain and the indignity of living one's final days incapacitated                                                                           
     and in agony is certainly `{a}t the heart of {} liberty . . . .'") (quoting                                                                      
Casey, 505 U.S. at 851, 112 S. Ct. at 2807).                                                                                                          
     I wonder how many minutes of Seeley's agony the Legislature and/or the                                                                           
majority of this court would endure before seeing the light.  Words are                                                                               
insufficient to convey the needless suffering which the merciless State has                                                                           
imposed.                                                                                                                                              
b.  Errant Precedent                                                                                                                                  
     The majority cites six cases to support its claim that marijuana may                                                                             
be constitutionally prohibited without deprivation of due process.  Most                                                                              
are distinguishable on their facts.  None are controlling precedent for                                                                               
this court in any event.  One is from another state; one from our Court of                                                                            
Appeals; one from the Supreme Court; four are from lower federal courts.                                                                              
Inferior federal court precedent is not binding on this court.  Home Ins.                                                                             
Co. of New York v. Northern Pac. Ry. Co., 18 Wn.2d 798, 808, 140 P.2d 507,                                                                            
147 A.L.R. 849 (1943).  Nor are decisions from other states; certainly not                                                                            
our Court of Appeals.  The Supreme Court case does not speak to the                                                                                   
constitution.                                                                                                                                         
     Carnohan v. United States, 616 F.2d 1120 (9th Cir. 1980) concerned                                                                               
laetrile, not marijuana, and was dismissed for failure to exhaust                                                                                     
administrative remedies.  But see Suenram v. Society Valley Hosp., 155                                                                                
N.J.Super. 593, 383 A.2d 143 (1977) (upholding constitutional due process                                                                             
right of cancer patient to ingest laetrile.).                                                                                                         
     People v. Privitera, 23 Cal. 3d 697, 591 P.2d 919, 153 Cal. Rptr. 431,                                                                           
5 A.L.R.4th 178, cert. denied, 444 U.S. 949, 100 S. Ct. 419, 62 L. Ed. 2d                                                                             
318 (1979) also concerned laetrile and is nonbinding precedent from another                                                                           
jurisdiction.                                                                                                                                         
     United States v. Rutherford, 442 U.S. 544, 99 S. Ct. 2470, 61 L. Ed.                                                                             
2d 68 (1979) is binding United States Supreme Court precedent, however, was                                                                           
decided solely on statutory, not constitutional, grounds.                                                                                             
     NORML v. Bell, 488 F. Supp. 123 (D.C. Cir. 1980), a U.S. District                                                                                
Court case, involved different issues raised in a challenge by recreational                                                                           
marijuana smokers, not a terminal cancer patient.  United States v. Fry,                                                                              
787 F.2d 903 (4th Cir.), cert. denied, 479 U.S. 861, 107 S. Ct. 209, 93 L.                                                                            
Ed. 2d 139 (1986) also involved issues distinctly different from those                                                                                
raised by Seeley.  State v. Dickamore, 22 Wn. App. 851, 592 P.2d 681 (1979)                                                                           
is (1) an inferior Court of Appeals case not binding on the Supreme Court                                                                             
and (2) factually distinct in that it involved only marijuana for                                                                                     
recreational use.                                                                                                                                     
     To the extent the majority finds support in these cases, I conclude                                                                              
they are inconsistent with the constitutional guarantee at issue,                                                                                     
erroneous, and ignoble repetitions of error.  Supreme Court cases cited in                                                                            
this dissent control the result and favor Seeley.  Ravin is also                                                                                      
persuasive.                                                                                                                                           
Conclusion                                                                                                                                            
     For the reasons stated I would hold the law in question, which                                                                                   
absolutely prohibits the sale, use, and/or ingestion of marijuana, deprives                                                                           
Mr. Seeley of his liberty absent that minimum process constitutionally due,                                                                           
and would therefore invalidate the statute and affirm the trial court on                                                                              
that basis.  Accordingly, I dissent.                                                                                                                  
                                                                                                                                                      
1 Joseph Sobran, The Wanderer 5 (June 26, 1997).                                                                                                      
                                                                                                                                                      
2 The Washington privileges and immunities clause provides:                                                                                           
                                                                                                                                                      
     No law shall be passed granting to any citizen, class of citizens, or                                                                            
corporation other than municipal, privileges or immunities which upon the                                                                             
same terms shall not equally belong to all citizens, or corporations.                                                                                 
                                                                                                                                                      
Wash. Const. art. I,  12.                                                                                                                             
                                                                                                                                                      
3 The federal equal protection clause provides:                                                                                                       
                                                                                                                                                      
No State shall . . . deny to any person within its jurisdiction the equal                                                                             
protection of the laws.                                                                                                                               
                                                                                                                                                      
U. S. Const. amend. 14,  1.                                                                                                                           
                                                                                                                                                      
4 The ACLU brief asserts the Washington statute prohibiting access to                                                                                 
medical marijuana in leaf form violates the substantive due process clause                                                                            
of the Fourteenth Amendment to the United States Constitution.  Amicus                                                                                
Brief of the American Civil Liberties Union of Washington Foundation (ACLU                                                                            
Amicus Brief) at 9.  This court has the authority to entertain the ACLU's                                                                             
arguments.  City of Tacoma v. Luvene, 118 Wn.2d 826, 832-33, 827 P.2d 1374                                                                            
(1992) (deciding preemption issue briefed only by amicus); Harris v.                                                                                  
Department Labor & Indus., 120 Wn.2d 461, 467-68, 843 P.2d 1056 (1993) (the                                                                           
appellate court has inherent authority to address issue raised only by                                                                                
amicus if necessary to reach a proper decision).  Here, the issue has been                                                                            
fully briefed by both sides.  See State of Washington's Answer to ACLU                                                                                
Amicus Brief.                                                                                                                                         
                                                                                                                                                      
5 Poe v. Ullman, 367 U.S. 497, 543, 81 S. Ct. 1752, 1777, 6 L. Ed. 2d 989                                                                             
(1961) (Harlan, J., dissenting) (quoting Hurtado v. California, 110 U.S.                                                                              
516, 532, 4 S. Ct. 111, 119, 28 L. Ed. 232 (1884)).                                                                                                   
                                                                                                                                                      
6 Seeley's doctor, Dr. Ernest Conrad III, Director of Musculoskeletal                                                                                 
Oncology at the University of Washington, states on the record, "In short,                                                                            
if I could prescribe marijuana for him {Seeley}, I would."  Clerk's Papers                                                                            
(CP) at 82.                                                                                                                                           
                                                                                                                                                      
7 The record is replete with uncontroverted evidence that Seeley and many                                                                             
similarly situated cancer patients undergo unbearable pain and digestive                                                                              
unrest as a result of chemotherapy and radiation treatments and that they                                                                             
claim leaf marijuana is one of the only efficacious agents available to                                                                               
ease their suffering.                                                                                                                                 
                                                                                                                                                      
8 Casey, 505 U.S. at 894 ("Legislation is measured for consistency with the                                                                           
Constitution by its impact on those whose conduct it affects. . . .  The                                                                              
proper focus of constitutional inquiry is the group for whom the law is a                                                                             
restriction, not the group for whom the law is irrelevant."  (Citation                                                                                
omitted.)).                                                                                                                                           
                                                                                                                                                      
9 Compare Glucksberg, 1997 WL 348094, *25-45 (Souter, J., concurring) where                                                                           
Justice Souter exhaustively reviews the legal history of substantive due                                                                              
process through the present day, concluding the Harlan dissent represents                                                                             
the appropriate analysis.                                                                                                                             
                                                                                                                                                      
10 Historically, marijuana has been used in a variety of ways.  The original                                                                          
Declaration of Independence (July 4, 1776) was written on hemp as was                                                                                 
Thomas Paine's Common Sense.  Jack Herer, The Emperor Wears No Clothes 7                                                                              
(1995).  George Washington and Thomas Jefferson grew it, and Benjamin                                                                                 
Franklin used it in an early papermill.  Marty Bergoffen & Roger Lee Clark,                                                                           
Hemp as an Alternative to Wood Fiber in Oregon, 11 J. Envtl. L. & Litig.                                                                              
119, 120 (1996).                                                                                                                                      
                                                                                                                                                      
Throughout the nineteenth century marijuana was used as an anticonvulsant,                                                                            
as an analgesic and in the treatment of rheumatism, epilepsy and tetanus.                                                                             
Lester Grinspoon, M.D., and James B. Bakalar, Marihuana, the Forbidden                                                                                
Medicine 5-6 (1993) (included in part in CP at 92-119).  Marijuana was                                                                                
administered to Queen Victoria by her court physician.  Id. at 4.  In                                                                                 
nineteenth century America marijuana was listed in the United States                                                                                  
Dispensatory (1854), was generally available in drug stores, and was                                                                                  
characterized in an early medical study as "a drug that has a special value                                                                           
in some morbid conditions and the intrinsic merit and safety of which                                                                                 
entitles it to a place once held in therapeutics."  Dr. J. B. Mattison,                                                                               
Cannabis indica as an Anodyne and Hypnotic, St. Louis Medical Surgical                                                                                
Journal 61, 266 (1891), quoted in Grinspoon & Bakalar, supra at 6.                                                                                    
                                                                                                                                                      
However, marijuana was repressed by the federal government in 1937 through                                                                            
a stamp tax so burdensome both financially and procedurally that it                                                                                   
virtually eliminated any legal medicinal, industrial or recreational use of                                                                           
marijuana.  26 U.S.C.  4741, repealed by Comprehensive Drug Abuse                                                                                     
Prevention and Control Act of 1970, tit. III,  1101(b)(3)(A), 84 Stat.                                                                                
1292.  The purpose of the tax was prohibition although it was effectuated                                                                             
in the form of a revenue measure because of constitutional limits still                                                                               
enforced against federal lawmaking power.  Grinspoon & Bakalar, supra at 8.                                                                           
The elimination of marijuana came from pressures exerted by newly created                                                                             
"Federal drug control agencies, cotton and timber interests, and chemical                                                                             
industries."  Bergoffen & Clark, supra at 122 n.20.  Marijuana was removed                                                                            
from the United States Pharmacopoeia and National Formulary in 1941.                                                                                  
                                                                                                                                                      
Shortly after the Marijuana Tax Act was held unconstitutional in 1969, in a                                                                           
failed attempt to prosecute Dr. Timothy Leary for possession of untaxed                                                                               
marijuana (Leary v. United States, 395 U.S. 6, 89 S. Ct. 1532, 23 L. Ed. 2d                                                                           
57 (1969) (marijuana tax unconstitutional as violative of the Fifth                                                                                   
Amendment's guarantee against self-incrimination)), Congress passed the                                                                               
Controlled Substances Act, placing marijuana in schedule I and directly                                                                               
criminalizing any use of it.  Washington followed suit in 1971 and adopted                                                                            
an identical regime also placing marijuana in schedule I.  Laws of 1971,                                                                              
1st Ex. Sess., ch. 308 at 1794 (Uniform Controlled Substances Act).                                                                                   
                                                                                                                                                      
11 Under Washington law, use of leaf marijuana is illegal for any purpose.                                                                            
RCW 69.50.204(d)(13).  Doctors may never prescribe it no matter how                                                                                   
efficacious it may be in a given case.  In contrast, Washington law allows                                                                            
doctors to prescribe cocaine, PCP angel dust, opium, and morphine.                                                                                    
RCW 69.50.206.                                                                                                                                        
                                                                                                                                                      
12 Compare Glucksberg, 1997 WL 348094 at *14 ("{P}hysician-assisted suicide                                                                           
is fundamentally incompatible with the physician's role as healer."                                                                                   
(Citation omitted.); (Souter, J., concurring) at *38-40 (Physician's care                                                                             
is within American tradition and is given "high value."  Dying patient who                                                                            
seeks help is subject to few state-imposed restraints.); Casey, 112 S. Ct.                                                                            
at 2810, 2830 (upholding the affirmative due process right to obtain                                                                                  
medical intervention).                                                                                                                                
                                                                                                                                                      
13 There is an intermediate standard not relevant here, used primarily in                                                                             
the equal protection context.  See, e.g., Griffin v. Eller, 130 Wn.2d 58,                                                                             
65, 922 P.2d 788 (1996); State v. Heiskell, 129 Wn.2d 113, 123, 916 P.2d                                                                              
366 (1996).                                                                                                                                           
                                                                                                                                                      
14 I must confess, even under this standard of virtual judicial abdication,                                                                           
I can still find no rational basis for this statute.                                                                                                  
                                                                                                                                                      
15 Compare Columbia Broadcasting Sys., Inc. v. Democratic Nat'l Comm., 412                                                                            
U.S. 94, 162, 93 S. Ct. 2080, 2109, 36 L. Ed. 2d 772 (1973) (Douglas, J.,                                                                             
concurring) ("The struggle for liberty has been a struggle against                                                                                    
Government.  The essential scheme of our Constitution and Bill of Rights                                                                              
was to take Government off the backs of people.").                                                                                                    
16 Such recognized "fundamental" liberty interests are catalogued in                                                                                  
Washington v. Harold Glucksberg, No. 96-110, 1997 WL 348094 (U.S. June 26,                                                                            
1997) (Souter, J., concurring) at *31-32.  Subjects include segregation in                                                                            
education, interracial marriage, marital privacy and contraception,                                                                                   
abortion, "personal control of medical treatment" (citing Cruzan) and                                                                                 
physical confinement.  Justice Souter criticizes what is our majority's                                                                               
approach as "absolutist" rather than weighing application of competing                                                                                
principles.