DeCano v. State

In DeCano v. State, 7 Wn.2d 613, 110 P.2d 627 (1941), the Court addressed an amendatory act which was titled "AN ACT relating to the rights and disabilities of aliens with respect to land, and amending . . . ." Id. at 623. However, the body of the act specifically defined "alien" in a way "which brings within its purview a whole new class of persons who are not in fact aliens in common understanding . . . ." Id. at 624. The court applied the rule that "'words in a title must be taken in their common and ordinary meanings, and the legislature cannot in the body of an act impose another or unusual meaning upon a term used in the title without disclosing such special meaning therein.'" Id. at 626. The court held that the act violated article II, section 19.