On January 14, 2025, the Governor's Office received the appeal you filed in response to the Washington State Gambling Commission's decision to deny your petition to amend WAC 230-15-135(1)(c). Under RCW 34.05.330(3), an agency's denial of a petition to repeal or amend a rule may be appealed to the Governor.

WAC 230-15-135 establishes the single-wager limits for nonhouse-banked games, including poker. For Class F and house-banked card game licensees, the limit for nonhouse-banked poker is $300. WAC 230-15-135(1)(c). Your petition to the Gambling Commission asked to amend WAC 230-15-135(1)(c) to raise this limit from $300 to $400 to be in line with the betting limits for house-banked card games established in WAC 230-15-140(1). Your petition argued for this change because "[t]he Commission is unwilling to remove the betting caps altogether"; the change would bring the limits for nonhouse-banked games "in line with the betting limits of house-banked card games"; and it would give poker "parity with other games."

The Commission's denial letter indicates that the Commission discussed your petition during its January 9, 2025 meeting. Following this discussion, the Commission denied your petition. In its denial letter, the Commission states that it denied your petition because "at this time an increase in raising the wager limit" for nonhouse-banked card games "is not consistent with the public policies of Washington to promote the social welfare of the people by limiting the nature and scope of gambling activities and by strict regulation and control as outlined in RCW 9.46.010," a provision of Washington's Gambling Act.

The Governor's Office received your appeal of the Commission's decision on January 14, 2025. Your appeal petition argues that there should be "parity between the betting caps for house-banked games and nonhouse-banked poker games," and that it makes "no sense" for blackjack—a house-banked game—to be subject to a different wager limit than nonhouse-banked poker. Your appeal petition argues that the denial of your petition was "arbitrary" and, further, that the Commission's reliance on the Gambling Act's declaration of public policy is unfounded. You note that the Commission raised the wager limit on house-banked games from $300 to $400 but rejected your petition for the same increase to the wager limit on nonhouse-banked poker games. But your appeal petition, like your initial petition to the Gambling Commission, did not offer any reason why there currently should be "parity" between the wager limits that apply when players bet against each other (as in nonhouse-banked poker) and those that apply when they bet against the casino (as in house-banked games).

Your proposed amendment to increase the wager limit for nonhouse-banked poker games presents a policy decision that implicates the legislative declaration of public policy in the Gambling Act. This public policy—to promote social welfare by limiting the nature and scope of gambling activities and by strict regulation and control—is indeed relevant and appropriate for the Commission to consider. After careful consideration, I am not persuaded that the Commission erred in denying your petition to amend WAC 230-15-135(1). Your appeal petition is denied.