Petroleum Lease Props., Inc. v. Huse
In Petroleum Lease Props., Inc. v. Huse, 195 Wash. 254, 260, 80 P.2d 774 (1938), the title of the act was "AN ACT providing for the regulation and supervision of the issuance and sale of securities to prevent fraud in the sale thereof, amending . . . ." Id. at 257.
In the body of this amendatory act the term "securities" was defined to include oil or gas leases. The court said:
"The title gives no notice that there is to be embodied in the amendment the regulation of any matter not embraced within the meaning of the word 'security' as that term is commonly understood and defined by standard dictionaries, as well as by the original securities act itself. That a gas or oil lease is not a 'security' as ordinarily understood, or as defined in the original act, is self-evident." Id. at 258.