Restrictive ?Good Cause to Quit? Legislation Violated Subject in Title Rule

As part of the giveaways to try to keep Boeing from relocating in 2003, the Legislature passed a bill placing drastic limitations on the grounds for ?good cause? to quit, for the purposes of receiving unemployment.?? ?An unemployment applicant challenged that part of the law on the basis that the subject? ?wasn?t? ?included? ?in?? the?? title?? of? ?the legislation, as required by Article ii, Section 19 of the Constitution.?? ESD agreed that the subject of ?good cause? was not included in the title of the 2003 legislation, but claimed that it was included in ?the ?title ?of ?a ?2006 ?bill ?that ?re-enacted ?the limitations. ?The title of the latter legislation said the 2006 bill made ?adjustments in the unemployment insurance system to enhance benefits and tax equity.? ?The employee said the ?good cause? limitations still did not fall within the title.?? Division I agreed and said claims of ?good cause? must be evaluated under the pre- 2003? standard.??? Batey? v. Employment? Security?Dep?t, 154 P.3d 266 (2007)