Anthony J. Predisik and Christopher Katke v. Spokane School District No. 81

Summary

The Washington Supreme Court held that public employees do not have a privacy right under the Public Records Act in the mere fact that their public employer is investigating them or has placed them on administrative leave. Because the records disclosed only the existence of the investigations and did not describe the underlying allegations, neither the personal-information nor investigative-record exemption applied, and the records were ordered disclosed in full.

Holdings

1. The Public Records Act does not recognize a privacy right in the mere fact that a public employer is investigating a public employee or in the employee's use of administrative leave. Because the records disclose only those facts and no private factual allegations, RCW 42.56.230(3) does not exempt them from disclosure.
2. The administrative-leave letter and leave-pay spreadsheets are not exempt investigative records under RCW 42.56.240(1) because they are neither essential to law enforcement nor essential to the protection of privacy.

Questions Presented

1. Whether the Public Records Act's personal-information exemption protects the identities of public employees when records disclose only that the employees are subjects of open employer investigations and are on administrative leave.
2. Whether the Public Records Act's investigative-record exemption protects the administrative-leave letter and leave-pay spreadsheets.
3. Whether the records must be disclosed in their entirety or with the employees' names redacted.

Disposition

reversed_and_remanded