State v. Chen

Summary

The Washington Supreme Court held that a competency evaluation becomes subject to the constitutional presumption of public access once it becomes a court record. The court ruled that RCW 10.77.210 does not impose a blanket privacy requirement overriding article I, section 10 of the Washington Constitution, and that sealing requires individualized findings under the Ishikawa factors. The court affirmed the trial court’s decision to redact portions of the evaluation rather than seal it in its entirety.

Holdings

1. Once a competency evaluation becomes a court record, it is presumptively open to public access under article I, section 10 of the Washington Constitution.
2. The presumption of openness may be overcome only upon an individualized finding that the Ishikawa factors favor sealing; when appropriate, redaction is preferred over wholesale sealing.
3. RCW 10.77.210 does not mandate sealing of a competency evaluation after the evaluation becomes a court record.
4. The trial court did not abuse its discretion because it properly considered the Ishikawa factors, found no significant amount of private health care information, and ordered redaction of particular information.

Questions Presented

1. Whether RCW 10.77.210 creates a presumption that a competency evaluation must remain private after it becomes a court record.
2. Whether a competency evaluation filed with the court is subject to the constitutional presumption of openness under article I, section 10 of the Washington Constitution.
3. Whether the trial court abused its discretion by refusing to seal the entire competency evaluation after applying the Ishikawa factors and ordering limited redactions.

Disposition

affirmed