Lyft, Inc. v. City of Seattle, 190 Wn. 2d 769

Summary

The Washington Supreme Court held that records containing trade secrets are not categorically exempt from disclosure under the Public Records Act. The court ruled that a party seeking to enjoin disclosure must satisfy the heightened standard in RCW 42.56.540, requiring a showing that disclosure would clearly not be in the public interest and would substantially and irreparably damage a person or vital government interest. The court reversed and remanded for application of that standard to Lyft and Rasier's zip-code reports.

Holdings

1. Records containing trade secrets are not categorically exempt from disclosure under the Public Records Act. The Uniform Trade Secrets Act may qualify as an applicable 'other statute' exemption in a particular case, but a trade-secret determination does not by itself authorize withholding the records.
2. The injunction standard in RCW 42.56.540 governs. A party seeking to prevent disclosure must establish that disclosure would clearly not be in the public interest and would substantially and irreparably damage a person or vital governmental functions.
3. The superior court's findings did not adequately address the heightened requirements of RCW 42.56.540. The permanent injunction had to be reversed and the matter remanded for application of the correct statutory standard.

Questions Presented

1. Whether the Uniform Trade Secrets Act categorically exempts records containing trade secrets from disclosure under the Washington Public Records Act.
2. Whether a party seeking to enjoin disclosure of public records containing trade secrets must satisfy the injunction standard in RCW 42.56.540 rather than the general CR 65 standard.
3. Whether the superior court adequately determined that disclosure would clearly not be in the public interest and would substantially and irreparably damage a person or vital governmental functions.

Disposition

reversed_and_remanded