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 factorso TM Thus, while the six factors continue to be cited as "none×elusive"
 and "relevant," they are in fact a necessary minimum Jf a party hopes to
 prevail, or even have the issue considered.
 The six factors and the relevance to the rnedica_t marijuana issue are as
 follows:
 1. The textual language of the_tate consfi_fion:
 "The text of the state constitution may provide cogent grotmds for a
 decision different from that which would be arrived at under the federal
 constitution° It may be more explicit or it may have no precise federal
 counterpart at all."s5
 There is no fedora1 counterpart to the "frequent recurrence to
 fundamental principles" of article I, § 32 of the Washington constitution
 (hereinafter, Section 32). If there were such a clause, it would be impossible
 for the federal bureaucracy to remain as unrestrained as it has now become,
 since a system of checks and balances and prevention of concentration of
 power are fundamental to prevention of tyranny and preservation of personal
 liberty. To prevail on the basis of simple, humanitarian decency, the words of
 the state constitution offer hope where t.he federal constitution offers none.
 2. Ngnificant _fferences in t_h_ texts of paralleJ. Novisions of the
 federal and state constitutions,
 "Such differences may also warrant reliance on the state constitution.
 Even where parallel provisions of the two constitutions do not have
 meaningful differences, other relevant provisions of the state constitution may
 require that the state constitutions may require that the state constitution be
 interpreted differenflyo TM
 It is tempting to find several attacks which might be launched under
 this rubric. Some examples:
 A. Rights ef privacy
 54 Among others, see _ 119 Wn.2d 466, 472, 755 P.2d 797 (1988); In re 2_lota. 114
 Wn.2d 465, 472, 788 P.2d 538 (1990)o
 55 I_ at 6I.
 56 I_.
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