tution and in harmony with such laws as the legislature
has or may hereafter enact. The city may adopt a charter which is in
harmony with the constitution and the laws of the state, but the charter
thus adopted may be freely modified by general laws relating to cities.
The unfriendly attitude of the courts has thus largely defeated the
object of these home-rule provisions. The state legislature is still
free to encroach upon or abridge the sphere of municipal
self-government.

The constitutional provisions above mentioned may be regarded as having
a twofold purpose. They were designed to limit, if not destroy, the
power of the legislature to invade the sphere of municipal affairs, and
also to confer upon cities the general power to act for themselves, by
virtue of which they could on their own initiative, subject to certain
restrictions contained in the constitution, set up their own government,
formulate and carry out a municipal policy and manage their own affairs
to suit themselves. This would seem to be implied necessarily in the
grant of constitutional power to frame a charter for their own
government. A liberal interpretation of this feature of the
constitutions in question would have held that all cities to which it
applied were thereby authorized to exercise all powers not expressly
withheld by the constitution or the statutes of the state. This,
however, has not been the attitude of the courts. Their reluctance to
give home-rule provisions a liberal interpretation may be illustrated by
a decision of the supreme court of Washington. In addition to the power
granted to cities of the first class to frame their own charters the
constitution of this state provides that "any county, city, town, or
township, may make and enforce within its limits all such local, police,
sanitary and other regulations as are not in conflict with general
laws." In view of the attitude that courts have generally taken in this
matter it is not surprising that the supreme court of Washington has
intimated that the above-mentioned constitutional provisions are not
self-executing. Moreover, it does not seem disposed to concede even to
cities of the first class any important powers except such as have been
expressly conferred by statute. For example, the statutes of Washington
authorize cities of the first class "to regulate and control the use" of
gas supplied by a private corporation, and the charter of Tacoma
expressly gave to the city cou