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Houser v. State

Supreme Court of Washington
540 P.2d 412 (1975)


Facts

Charles Houser, III (plaintiff) brought a  declaratory judgment action against various Washington State agencies (the State) (defendant) to have the underage drinking law, which established the minimum drinking-age as twenty-one, declared unconstitutional. Houser asserted that the law deprived himself and other eighteen-to-twenty year olds in Washington state of equal protection under the law because there was no rational relationship between restricting the right of adults aged eighteen to twenty to possess and consume alcohol and a legitimate state purpose. To support this argument, Houser submitted to the court an expert statement refuting the traditional arguments for setting the minimum drinking age at twenty-one. The State moved for summary judgment and asked the court to take judicial notice of two technical studies that supported the twenty-one year old drinking-age restriction and a federal case, Republican College Council v. Winner, 357 F. Supp. 739 (1973), which held that Pennsylvania’s underage drinking law did not violate equal protection. Relying on these technical studies and Republican College Council, the district court granted the State’s motion for summary judgment, holding that the studies and Republican College Council were sufficient for the court to determine that there was a rational relationship between the drinking age and a legitimate state purpose. Houser appealed the trial court’s grant of summary judgment to the Washington Supreme Court, claiming that the trial court should not have taken judicial notice of the studies because they were not “well established and authoritatively settled.” Houser also argued that the court should not have granted summary judgment without a trial on the merits to resolve disputed factual issues.

Rule of Law

Issue

Holding and Reasoning (Utter, J.)

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