Associated Press v. Washington State Legislature, 193 Wn. 2d 110

438 P.3d 1211 (2019) · Supreme Court of the State of Washington · December 19, 2019 · No. 95441-1

Summary

The Washington Supreme Court addresses whether the state legislative branch is subject to the Public Records Act. It holds that individual legislators’ offices are agencies subject to the Act’s general disclosure mandate, while the institutional Senate, House of Representatives, and Legislature are subject to a narrower mandate administered through the Secretary of the Senate and Chief Clerk of the House. The court affirms the trial court’s judgment.

Holdings

  1. Individual legislators' offices are agencies subject to the Public Records Act's general public-records disclosure mandate.
  2. The Senate, House of Representatives, and legislature as a whole are not agencies subject to the Public Records Act's general disclosure mandate. They are instead subject to the Act's narrower disclosure mandate through the secretary of the senate and chief clerk of the house.

Questions Presented

  1. Whether individual legislators' offices are agencies subject to the Public Records Act's general public-records disclosure mandate.
  2. Whether the institutional legislative bodies—the Senate, House of Representatives, and legislature as a whole—are agencies subject to the Public Records Act's general public-records disclosure mandate.

Disposition

affirmed

Cases Cited (26)

  • Dep't of Ecology v. Campbell & Gwinn, LLC, 146 Wn. 2d 1, 43 P.3d 4 (2002)(followed)
  • City of Federal Way v. Koenig, 167 Wn. 2d 341, 217 P.3d 1172 (2009)(followed)
  • Hisle v. Todd Pac. Shipyards Corp., 151 Wn. 2d 853, 93 P.3d 108 (2004)(followed)
  • Whatcom County v. City of Bellingham, 128 Wn. 2d 537, 909 P.2d 1303 (1996)(followed)
  • Bainbridge Island Police Guild v. City of Puyallup, 172 Wn. 2d 398, 259 P.3d 190 (2011)(followed)
  • Hearst Corp. v. Hoppe, 90 Wn. 2d 123, 580 P.2d 246 (1978)(followed)
  • State v. Sullivan, 143 Wn. 2d 162, 19 P.3d 1012 (2001)(followed)
  • Jametsky v. Olsen, 179 Wn. 2d 756, 317 P.3d 1003 (2014)(distinguished)
  • State v. Barnes, 189 Wn. 2d 492, 403 P.3d 72 (2017)(distinguished)
  • Davis v. Dep't of Licensing, 137 Wn. 2d 957, 977 P.2d 554 (1999)(distinguished)

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