III. Plaintiffs’ Complaint

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 expedite their trials, to seek reconsideration of the continuances, or to seek appellate review. Id. Their case dockets include no filings seeking such relief. See Martin Exs. C-F.

III. Plaintiffs’ Complaint

Instead of raising their constitutional concerns in the courts where their cases are pending, Plaintiffs filed this separate lawsuit. They contend that the State’s “unconstitutionally inadequate funding” of the judiciary has violated their constitutional rights and those of “thousands” of other civil litigants across Washington. FAC ¶ 5.85. Specifically, they allege that the State’s budget violates the separation-of-powers doctrine and three provisions of article I of the Washington Constitution: section 29, which confirms that constitutional provisions are “mandatory”; section 10, which guarantees open courts and “[j]ustice . . . without unnecessary delay”; and section 21, which enshrines the right to a jury trial. FAC ¶¶ 6.1-8.3. Plaintiffs request a declaration that their rights under these provisions were violated, along with breathtakingly expansive injunctive (or mandamus) relief. FAC ¶¶ 9.1-9.2. Plaintiffs ask the Court to order the State to provide eighteen categories of funding, including interpreters, civil legal aid, law libraries, “[h]elp for self-represented persons,” “[e]ducation for judicial officers and staff,” additional judges and staff, enhanced courthouse security, technology, and infrastructure. FAC ¶¶ 10.4, 11.1. In sum, Plaintiffs seek wholesale judicial oversight of judicial funding by the State based on their civil trial continuances.

MOTION TO DISMISS Case No. 21-2-06462-7 SEA 9

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