State v. Hovrud

Petrich, J.

(dissenting) — I dissent. The Insurance Commissioner, in a legislatively authorized action, specifically approved the standard form insurance policy at issue in *577this case. WAC 284-20-010(3) says in part that "no company shall issue any basic contract of fire insurance covering property or interest therein in this state other than on the form known as the 1943 New York Standard Fire Insurance Policy . . .". While the remainder of this regulation allows an insurance company to adopt a policy more favorable to the insured, the policy at issue here is identical to the standard policy adopted in the regulation. As such, the oath required under Hovrud's policy was "specifically provided for by statute or regulatory provision" and, therefore, was "required or authorized by law." RCW 9A.72-.010(3); RCW 9A.72.040. Cf. People v. Watson, 85 Ill. App. 3d 649, 406 N.E.2d 1148, 1151 (1980) (permissive oath is "required by law" if the statement must be sworn to before it can be used for the legal purpose intended).

The state of Wisconsin had a statute imposing a criminal sanction for false swearing much like RCW 9A.72.040. In State v. Devitt, 82 Wis. 2d 262, 262 N.W.2d 73 (1978), the Wisconsin court held that a false statement regarding campaign contributions made under oath by a member of a campaign organization for an unsuccessful candidate seeking a party endorsement was not subject to criminal liability for "false swearing." The court reasoned that the Corrupt Practices Act only required such a statement from an organization supporting a candidate for the primary or general election. Because the person involved never qualified as a candidate, the supporting organization was not required to submit the report under oath. Important to our case is the distinction the court made regarding statements authorized but not required by law:

The felony false swearing statute is a statute of general application that can apply to a multitude of situations. There are instances where the filing of a sworn statement can be authorized by law but not required by law, such as an affidavit in support of a motion in a legal proceeding, or an affidavit or statement in support of an application for various forms of license. In these and like instances the sworn statement is not required but is authorized and designed to favorably influence the position of the person offering the statement. The purpose of the Corrupt Practice Act, as it was at the time in question, *578was not to authorize the filing of the financial statement but to require it to be done when an individual was a candidate for a nomination or election. If he was not required to do so, as the parties agree, the inadvertent filing should not subject him to a felony conviction.

State v. Devitt, supra at 270. Conceivably, the oath specified in the 1943 New York Standard Fire Insurance Policy may not be required by law since the Insurance Commissioner might well approve of an insurance policy form without such an oath as an alternative form of policy, but nevertheless the oath was clearly authorized by the regulation.

The majority focuses on the lack of any oath requirement in the regulation. It then concludes that because an oath is not specifically provided for, the oath was not required or authorized by law. Such an analysis ignores well-settled rules for interpreting legislative acts when other acts are adopted by reference. The referenced terms are considered and treated as if they were incorporated into and made a part of the referring act, just as completely as if they had been explicitly written therein. Knowles v. Holly, 82 Wn.2d 694, 700-01, 513 P.2d 18 (1973). In my view, the same analysis should be applied in interpreting a regulation which adopts by reference an existing and well-defined document such as the standard policy specified in the regulation.4

Furthermore, I dissent because the majority inappropriately relies on State v. Dougall, 89 Wn.2d 118, 570 P.2d 135 (1977). Dougall involved two challenges to the constitutionality of the Uniform Controlled Substances Act (RCW *57969.50): the violation of procedural due process and the unconstitutional delegation of legislative authority. As neither of these issues even remotely exists in the present case, the majority inappropriately extends Dougall's holding.

I am satisfied that the oath specified in the 1943 New York Standard Fire Insurance Policy was specifically authorized by law.

I would reverse.

Reconsideration denied April 2, 1991.

Review denied at 117 Wn.2d 1005 (1991).

The majority asserts that incorporation by reference is inappropriate when the statute does not even refer to the statute being referenced. That is not the case before us. A plain reading of WAC 284-20-010(3) reveals that the policy at issue is specifically referred to and adopted.

The majority also complains that incorporation by reference is irreconcilable with strict construction principles. First, those principles only apply when there is an ambiguity in the statute; here there is none. Second, even if the rules did apply, the majority ignores the clear principle that a statute should not be construed "in a forced, narrow or overly strict manner so as to defeat the intent of the Legislature." State v. Sayler, 36 Wn. App. 230, 235, 673 P.2d 870 (1983).