67 Washington opinions name it 2 courts 2009–2026 24 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Pasco Police Officers' Ass'n v. City of Pascogreen2 sentences2014See Pasco Police Officers' Ass'n v. City of Pasco, 132 Wn.2d 450, 469 , 938 P.2d 827 (1997) (noting that "[w]hether a party has failed to negotiate in good faith, although involving a substantial factual component, is a mixed question of law and fact."); Tapper v. Emp't Sec. 2013See Pasco Police Officers’ Ass’n v. City of Pasco, 132 Wn.2d 450, 469 , 938 P.2d 827 (1997) (noting that “[w]hether a party has failed to negotiate in good faith, although involving a substantial factual component, is a mixed question of law and fact”); Tapper v. Emp’t Sec. | 3 | 3 |
PASCO POLICE OFFICERS'ASS'N v. City of Pascogreen2 sentences2014See Pasco Police Officers' Ass'n v. City of Pasco, 132 Wn.2d 450, 469 , 938 P.2d 827 (1997) (noting that "[w]hether a party has failed to negotiate in good faith, although involving a substantial factual component, is a mixed question of law and fact."); Tapper v. Emp't Sec. 2013See Pasco Police Officers’ Ass’n v. City of Pasco, 132 Wn.2d 450, 469 , 938 P.2d 827 (1997) (noting that “[w]hether a party has failed to negotiate in good faith, although involving a substantial factual component, is a mixed question of law and fact”); Tapper v. Emp’t Sec. | 3 | 3 |
Yousoufian v. Office of Simsgreen2 sentences2019Hoffman asks us to engage in de novo review oftwo ofthe Yousoufian II factors that guide trial courts as they exercise this discretion, "the agency's good faith, honest, timely, and strict compliance with all 11 Hoffman v. Kittitas County, No. 96286-3 PRA procedural requirements and exceptions," a mitigator, and the agency's "negligent, reckless, wanton, bad faith, or intentional noncompliance with the PRA," an aggravator. 168 Wn.2d at 467-68 (footnote omitted). 2019Hoffman asks us to engage in de novo review oftwo ofthe Yousoufian II factors that guide trial courts as they exercise this discretion, "the agency's good faith, honest, timely, and strict compliance with all 11 Hoffman v. Kittitas County, No. 96286-3 PRA procedural requirements and exceptions," a mitigator, and the agency's "negligent, reckless, wanton, bad faith, or intentional noncompliance with the PRA," an aggravator. 168 Wn.2d at 467-68 (footnote omitted). | 2 | 8 |
Andrews v. Washington State Patrolgreen2 sentences2026We have previously observed that the purpose of the PRA is to keep agencies accountable in responding to public records requests with reasonable thoroughness and diligence, not to impose “a mechanically strict finding of a PRA violation whenever [internally imposed] timelines are missed.” Andrews, 183 Wn. 2026We have previously observed that the purpose of the PRA is to keep agencies accountable in responding to public records requests with reasonable thoroughness and diligence, not to impose “a mechanically strict finding of a PRA violation whenever [internally imposed] timelines are missed.” Andrews, 183 Wn. | 2 | 4 |
Lyft, Inc. v. City of Seattlegreen2 sentences2025Lyft, Inc. v. City of Seattle, 190 Wn.2d 769, 796 (2018). 2025Lyft, Inc. v. City of Seattle, 190 Wn.2d 769, 796 (2018). | 2 | 2 |
Faulkner v. Department of Correctionsgreen2 sentences2026Faulkner v. Dep’t of Corr., 183 Wn. 2015One acting wantonly may be creating no greater risk of harm, but he is not trying to avoid it and is indifferent to whether harm results or not.” Id. at 103-04 (internal quotation marks omitted) (quoting Black’s Law Dictionary, supra, at 1720). ¶31 “Whether an agency acted in bad faith under the PRA presents a mixed question of law and fact, in that it requires the application of legal precepts (the definition of ‘bad faith’) to factual circumstances (the details of the PRA violation).” Francis, 178 Wn. | 1 | 4 |
Yousoufian v. Office of Ron Simsgreen2 sentences2016Yousoufian v. Office of Ron Sims, 168 Wn.2d 444, 458 , 229 P.3d 735 (2010) (’Yousoufian II). 2016Yousoufian v. Office of Ron Sims, 168 Wn.2d 444, 458 , 229 P.3d 735 (2010) (’Yousoufian II). | 1 | 3 |
Wade's Eastside Gun Shop, Inc. v. Department of Labor & Industriesgreen2 sentences2024A RCW 42.56.550(4) provides that “it shall be within the discretion of the court to award such person an amount not to exceed one hundred dollars for each day that he or she was denied the right to inspect or copy said public record.” (Emphasis added.) Accordingly, our Supreme Court instructed, “the plain language of the [Public Records Act (PRA)] confers great discretion on trial courts to determine the appropriate penalty for a PRA violation.” Wade’s Eastside Gun Shop, Inc. v. Dep’t of Labor & Indus., 185 Wn.2d 270, 278 , 372 P.3d 97 (2016). 2024A RCW 42.56.550(4) provides that “it shall be within the discretion of the court to award such person an amount not to exceed one hundred dollars for each day that he or she was denied the right to inspect or copy said public record.” (Emphasis added.) Accordingly, our Supreme Court instructed, “the plain language of the [Public Records Act (PRA)] confers great discretion on trial courts to determine the appropriate penalty for a PRA violation.” Wade’s Eastside Gun Shop, Inc. v. Dep’t of Labor & Indus., 185 Wn.2d 270, 278 , 372 P.3d 97 (2016). | 1 | 2 |
Belenski v. Jefferson Countygreen2 sentences2023And the court in Belenski stated that a final, definitive response started the statute of limitations even if the response was untruthful or incorrect. 186 Wn.2d at 461 . 2023And the court in Belenski stated that a final, definitive response started the statute of limitations even if the response was untruthful or incorrect. 186 Wn.2d at 461 . | 1 | 2 |
State v. SOLLESVIKgreen2 sentences2014App. 235, 244 , 258 P. 3d 78 ( 2011), review denied, 173 Wn.2d 1020 2012) ( whether PRA violation entitles requestor to penalty award was matter for trial court to consider on remand). 4 The Port requests attorney fees on appeal under RCW 4. 84. 185, which allows a party who prevails in opposing a frivolous action to recover attorney fees. 2014App. 235, 244 , 258 P.3d 78 (2011) (whether PRA violation entitles requestor to penalty award was matter for trial court to consider on remand), review denied, 173 Wn.2d 1020 (2012). ¶27 We reverse the trial court’s dismissal of West’s PRA complaint and order that the Port produce the investigation report without redactions of the employee’s identifying information. | 1 | 2 |
Spokane Research & Defense Fund v. City of Spokanegreen2 sentences2011Spokane Research, 155 Wash.2d at 105 , 117 P.3d 1117 . ¶ 13 Although Spokane Research states that the civil rules are an appropriate method to prosecute a PRA claim, there is no authority in the civil rules to limit their application to plaintiffs. 2011Spokane Research, 155 Wash.2d at 105 , 117 P.3d 1117 . ¶ 13 Although Spokane Research states that the civil rules are an appropriate method to prosecute a PRA claim, there is no authority in the civil rules to limit their application to plaintiffs. | 1 | 2 |
DeHeer v. Seattle Post-Intelligencergreen2 sentences2025DeHeer v. Seattle Post-Intelligencer, 60 Wn.2d 122, 126 , 372 P.2d 193 (1962) (“Where no authorities are cited in support of a proposition, the court is not required to search out authorities, but may assume that counsel, after diligent search, has found none.”). 2025DeHeer v. Seattle Post-Intelligencer, 60 Wn.2d 122, 126 , 372 P.2d 193 (1962) (“Where no authorities are cited in support of a proposition, the court is not required to search out authorities, but may assume that counsel, after diligent search, has found none.”). | 1 | 1 |
| Soter v. Cowles Pub. Co.green | 1 | 1 |
| Soter v. Cowles Publishing Co.green | 1 | 1 |
| Jeff Zink, et ux v. City of Mesagreen | 1 | 1 |
| Yakima County v. Yakima Herald-Republicgreen | 1 | 1 |
| Yakima v. Yakima Herald-Republicgreen | 1 | 1 |
| In re the Marriage of Sagnergreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Francis v. Department of Corrections
green
2 sentences2026When Haugen sent Gray the second installment of documents, he explained to Gray that building inspections were only conducted every three years, and annual reports were backlogged because of staffing shortages and disruption related to the COVID 3 “Whether an agency acted in bad faith under the PRA presents a mixed question of law and fact, in that it requires the application of legal precepts (the definition of ‘bad faith’) to factual circumstances (the details of the PRA violation).” Francis v. Dep't of Corr., 178 Wn. 2024“Whether an agency acted in bad faith under the PRA presents a mixed question of law and fact, in that it requires the application of legal precepts (the definition of ‘bad faith’) to factual circumstances (the details of the PRA violation).” Francis v. Dep’t of Corr., 178 Wn. | 7 | 2014–2026 |
Newman v. King County
green
2 sentences2013RCW 42.56.030; Cowles Publ’g Co. v. Spokane Police Dep’t, 139 Wn.2d 472, 476 , 987 P.2d 620 (1999); Newman, 133 Wn.2d at 571 . 2013RCW 42.56.030; Cowles Pub! 'g Co. v. Spokane Police Dep 't, 139 Wn.2d 472, 476 , 987 P.2d 620 (1999); Newman, 133 Wn.2d at 571 . | 4 | 2010–2013 |
David O'dea, Resp/cross App V. City Of Tacoma, Apps/cross Resps
neutral
2 sentences2026App. 2d 67 , 79, 493 P.3d 1245 (2021). 2026App. 2d 67 , 79, 493 P.3d 1245 (2021). | 3 | 2024–2026 |
Hobbs v. Washington State Auditor's Office
green
2 sentences2024Gronquist challenges the denial of his motion to reconsider and request for additional time to conduct discovery. 10 As this court opined in Hobbs: “As a policy matter, the purpose of the PRA is best served by communication between agencies and requesters, not by playing ‘gotcha’ with litigation.” Hobbs, 183 Wn. 2015Hobbs contended that, once an agency has allegedly violated the PRA, that PRA violation exists as a basis for penalties and costs from the time of alleged violation until it is cured, even if it is cured before the requestor would have a cause of action against the agency (i.e., when the agency takes final action in denying public records). 183 Wn. | 2 | 2015–2024 |
Doe v. Washington State Patrol
green
2 sentences2023THE COUNTIES DID NOT VIOLATE THE PRA IN DENYING DISCLOSURE AND COPYING OF BALLOT RECORDS BASED ON AN “OTHER STATUTE” EXEMPTION A. The PRA and the standard of review The PRA is a “strongly worded mandate for [the] broad disclosure of public records.” Hearst Corp. v. Hoppe, 90 Wn.2d 123, 127 , 580 P.2d 246 (1978); Doe v. Wash. State Patrol, 185 Wn.2d 363, 371 , 374 P.3d 63 (2016). 2023THE COUNTIES DID NOT VIOLATE THE PRA IN DENYING DISCLOSURE AND COPYING OF BALLOT RECORDS BASED ON AN “OTHER STATUTE” EXEMPTION A. The PRA and the standard of review The PRA is a “strongly worded mandate for [the] broad disclosure of public records.” Hearst Corp. v. Hoppe, 90 Wn.2d 123, 127 , 580 P.2d 246 (1978); Doe v. Wash. State Patrol, 185 Wn.2d 363, 371 , 374 P.3d 63 (2016). | 2 | 2018–2023 |
Hearst Corp. v. Hoppe
green
2 sentences2023THE COUNTIES DID NOT VIOLATE THE PRA IN DENYING DISCLOSURE AND COPYING OF BALLOT RECORDS BASED ON AN “OTHER STATUTE” EXEMPTION A. The PRA and the standard of review The PRA is a “strongly worded mandate for [the] broad disclosure of public records.” Hearst Corp. v. Hoppe, 90 Wn.2d 123, 127 , 580 P.2d 246 (1978); Doe v. Wash. State Patrol, 185 Wn.2d 363, 371 , 374 P.3d 63 (2016). 2023THE COUNTIES DID NOT VIOLATE THE PRA IN DENYING DISCLOSURE AND COPYING OF BALLOT RECORDS BASED ON AN “OTHER STATUTE” EXEMPTION A. The PRA and the standard of review The PRA is a “strongly worded mandate for [the] broad disclosure of public records.” Hearst Corp. v. Hoppe, 90 Wn.2d 123, 127 , 580 P.2d 246 (1978); Doe v. Wash. State Patrol, 185 Wn.2d 363, 371 , 374 P.3d 63 (2016). | 2 | 2011–2023 |
NEIGHBORHOOD ALLIANCE OF SPOKANE v. Spokane
green
2 sentences2021Id. 2021Id. | 2 | 2020–2021 |
Progressive Animal Welfare Society v. University of Washington
green
2 sentences2018Hoffman cites Progressive Animal Welfare Soc’y v. Univ. of Wash., 125 Wn.2d 243, 269 , 884 P.2d 592 (1994) (PAWS) (plurality opinion) for the proposition that an agency’s PRA violation should be assessed according to the agency’s “weakest link.” Br. of Appellant at 4. 2018Hoffman cites Progressive Animal Welfare Soc’y v. Univ. of Wash., 125 Wn.2d 243, 269 , 884 P.2d 592 (1994) (PAWS) (plurality opinion) for the proposition that an agency’s PRA violation should be assessed according to the agency’s “weakest link.” Br. of Appellant at 4. | 2 | 2018–2018 |
Yacobellis v. City of Bellingham
green
2 sentences2018Yacobellis, 64 Wn. 2018Yacobellis, 64 Wn. | 2 | 2018–2018 |
Rental Housing Ass'n v. City of Des Moines
green
2 sentences2016Ass’n of Puget Sound v. City of Des Moines, 165 Wn.2d 525, 536 , 199 P.3d 393 (2009) (explaining that where the meaning of statutory language is plain, the court must give effect to that plain meaning). ¶15 Furthermore, the plain language of the PRA confers great discretion on trial courts to determine the appropriate penalty for a PRA violation. 2016Ass’n of Puget Sound v. City of Des Moines, 165 Wn.2d 525, 536 , 199 P.3d 393 (2009) (explaining that where the meaning of statutory language is plain, the court must give effect to that plain meaning). ¶15 Furthermore, the plain language of the PRA confers great discretion on trial courts to determine the appropriate penalty for a PRA violation. | 2 | 2016–2016 |
RENTAL HOUSING ASS'N v. City of Des Moines
green
2 sentences2016Ass’n of Puget Sound v. City of Des Moines, 165 Wn.2d 525, 536 , 199 P.3d 393 (2009) (explaining that where the meaning of statutory language is plain, the court must give effect to that plain meaning). ¶15 Furthermore, the plain language of the PRA confers great discretion on trial courts to determine the appropriate penalty for a PRA violation. 2016Ass’n of Puget Sound v. City of Des Moines, 165 Wn.2d 525, 536 , 199 P.3d 393 (2009) (explaining that where the meaning of statutory language is plain, the court must give effect to that plain meaning). ¶15 Furthermore, the plain language of the PRA confers great discretion on trial courts to determine the appropriate penalty for a PRA violation. | 2 | 2016–2016 |
West v. STATE DEPT. OF NATURAL RESOURCES
green
2 sentences2014App. 235, 244 , 258 P. 3d 78 ( 2011), review denied, 173 Wn.2d 1020 2012) ( whether PRA violation entitles requestor to penalty award was matter for trial court to consider on remand). 4 The Port requests attorney fees on appeal under RCW 4. 84. 185, which allows a party who prevails in opposing a frivolous action to recover attorney fees. 2014App. 235, 244 , 258 P.3d 78 (2011) (whether PRA violation entitles requestor to penalty award was matter for trial court to consider on remand), review denied, 173 Wn.2d 1020 (2012). ¶27 We reverse the trial court’s dismissal of West’s PRA complaint and order that the Port produce the investigation report without redactions of the employee’s identifying information. | 2 | 2014–2014 |
Cowles Publishing Co. v. Spokane Police Department
green
2 sentences2013RCW 42.56.030; Cowles Publ’g Co. v. Spokane Police Dep’t, 139 Wn.2d 472, 476 , 987 P.2d 620 (1999); Newman, 133 Wn.2d at 571 . 2013RCW 42.56.030; Cowles Publ’g Co. v. Spokane Police Dep’t, 139 Wn.2d 472, 476 , 987 P.2d 620 (1999); Newman, 133 Wn.2d at 571 . | 2 | 2013–2013 |
American Civil Liberties Union v. Blaine School District No. 503
green
2 sentences2009The trial court based its low $15 per day penalty on American Civil Liberties Union of Washington v. Blaine School District No. 503, 95 Wash. App. 106 , 975 P.2d 536 (1999). 2009The trial court based its low $15 per day penalty on American Civil Liberties Union of Washington v. Blaine School District No. 503, 95 Wn. | 2 | 2009–2009 |
Rebecca A. Rufin, Appellant, v. the City of Seattle, Respondent
neutral
2 sentences2025App. 348, 354-55 , 398 P.3d 1237 (2017) (addressing a PRA claim). 2025App. 348, 354-55 , 398 P.3d 1237 (2017) (addressing a PRA claim). | 1 | 2025–2025 |
State v. Lowenthal
green
2 sentences2024Bad faith and the availability of penalties When an incarcerated person prevails on a PRA claim, the availability of penalties turns on whether the agency’s denial of responsive records was the product of “bad faith.” RCW 42.56.565(1). “[T]o establish bad faith, an inmate must demonstrate a wanton or willful act or omission by the agency.” Faulkner v. Dep’t of Corr., 183 Wn. 14 No. 39608-8-III Haney v. Dep’t of Corr. 2024Bad faith and the availability of penalties When an incarcerated person prevails on a PRA claim, the availability of penalties turns on whether the agency’s denial of responsive records was the product of “bad faith.” RCW 42.56.565(1). “[T]o establish bad faith, an inmate must demonstrate a wanton or willful act or omission by the agency.” Faulkner v. Dep’t of Corr., 183 Wn. 14 No. 39608-8-III Haney v. Dep’t of Corr. | 1 | 2024–2024 |
Kittitas County v. Sky Allphin
green
1 sentence2024Mr. Allphin appealed, claiming the County: (1) made improper claims that documents were exempt from attorney-client privilege, (2) wrongfully withheld and then subsequently produced certain records, (3) intentionally and wrongfully delayed its response, (4) unlawfully deleted or lost responsive public records, (5) overbroadly redacted or withheld hundreds of records with no claim of exemption, and (6) wrongfully 3 No. 39290-2-III Kittitas County v. Sky Allphin deleted or withheld the “‘smoking gun memorandum.’” Kittitas County v. Allphin, 195 Wn. | 1 | 2024–2024 |
Kinney v. Cook
green
2 sentences2024King County’s motion is granted. -8- No. 85983-8-I/9 award of attorney fees and costs to the opposing party.” Kinney v. Cook, 150 Wn. 2024King County’s motion is granted. -8- No. 85983-8-I/9 award of attorney fees and costs to the opposing party.” Kinney v. Cook, 150 Wn. | 1 | 2024–2024 |
| Bainbridge Island Police Guild v. City of Puyallup green | 1 | 2023–2023 |
| Morgan v. City of Federal Way green | 1 | 2023–2023 |
| Morgan v. City of Federal Way green | 1 | 2023–2023 |
| BAINBRIDGE POLICE GUILD v. City of Puyallup green | 1 | 2023–2023 |
| LaPlante v. State green | 1 | 2021–2021 |
| Block v. City of Gold Bar green | 1 | 2020–2020 |
| Amren v. City of Kalama green | 1 | 2019–2019 |
| Amren v. City of Kalama green | 1 | 2019–2019 |
| State v. Burks neutral | 1 | 2019–2019 |
| State v. Zander neutral | 1 | 2019–2019 |
| Benton County v. Donna Zink green | 1 | 2019–2019 |
| Mitchell v. STATE DEPT. OF CORRECTIONS green | 1 | 2019–2019 |
| Mitchell v. Department of Corrections green | 1 | 2019–2019 |
| Yousoufian v. Office of Ron Sims green | 1 | 2018–2018 |
| In Re Dependency of KB green | 1 | 2018–2018 |
| Yousoufian v. Office of King County Executive green | 1 | 2018–2018 |
| MAI Systems Corp. v. Peak Computer, Inc. green | 1 | 2018–2018 |
| Kleven v. City of Des Moines green | 1 | 2018–2018 |
| Rioux v. Department of Social & Health Services green | 1 | 2018–2018 |
| Resident Action Council v. Seattle Housing Authority green | 1 | 2016–2016 |
| Spokane Police Guild v. Liquor Control Board green | 1 | 2016–2016 |
| Johnson v. STATE DEPT. OF CORRECTIONS green | 1 | 2015–2015 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.