PRA injunction standard (Washington) · Go Syfert
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PRA injunction standard in Washington

9 Washington opinions name it 2 courts 2014–2025 4 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.

Followed or applied (4)

CaseFollowedCited
Lyft, Inc. v. City of Seattlegreen
wash · 2018 · cited in 5 Washington opinions naming this issue, 2018–2025
2 sentences

2025It also rejected the two-part PRA injunction standard set forth in RCW 42.56.540 and Lyft, Inc. v. City of Seattle, 190 Wn.2d 769 , 418 P.3d 102 (2018), reasoning that “establishment of the [First Amendment] right itself mandates the issuance of an injunction.” Does II, 27 Wn.

2025It also rejected the two-part PRA injunction standard set forth in RCW 42.56.540 and Lyft, Inc. v. City of Seattle, 190 Wn.2d 769 , 418 P.3d 102 (2018), reasoning that “establishment of the [First Amendment] right itself mandates the issuance of an injunction.” Does II, 27 Wn.

35
Spokane Police Guild v. Liquor Control Boardgreen
wash · 1989 · cited in 3 Washington opinions naming this issue, 2018–2025
2 sentences

2025Lyft, 190 Wn.2d at 790-91, 779-80 (if the information is exempt, “then ‘judicial inquiry commences’ with the court applying the PRA injunction standard” (quoting Spokane Police Guild, 112 Wn.2d at 36 )); Bainbridge Island Police Guild v. City of Puyallup, 172 Wn.2d 398, 408 , 259 P.3d 190 (2011) (plurality opinion).

2025Lyft, 190 Wn.2d at 790-91, 779-80 (if the information is exempt, “then ‘judicial inquiry commences’ with the court applying the PRA injunction standard” (quoting Spokane Police Guild, 112 Wn.2d at 36 )); Bainbridge Island Police Guild v. City of Puyallup, 172 Wn.2d 398, 408 , 259 P.3d 190 (2011) (plurality opinion).

23
Soter v. Cowles Pub. Co.green
wash · 2007 · cited in 2 Washington opinions naming this issue, 2025–2025
2 sentences

2025No. 102182-8 the exemption at issue is expressly set out in the PRA or incorporated via an ‘other statute’” (citing PAWS, 125 Wn.2d at 258 ; Spokane Police Guild, 112 Wn.2d at 36, 39 )); see also Soter v. Cowles Publ’g Co., 162 Wn.2d 716, 757 , 174 P.3d 60 (2007) (plurality opinion).

2025No. 102182-8 the exemption at issue is expressly set out in the PRA or incorporated via an ‘other statute’” (citing PAWS, 125 Wn.2d at 258 ; Spokane Police Guild, 112 Wn.2d at 36, 39 )); see also Soter v. Cowles Publ’g Co., 162 Wn.2d 716, 757 , 174 P.3d 60 (2007) (plurality opinion).

22
Seattle Times Co. v. Serkogreen
wash · 2010 · cited in 1 Washington opinions naming this issue, 2023–2023
1 sentence

2023See, e.g., Seattle Times Co., 170 Wn.2d 581 (discussed infra at 9-10).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Morgan v. City of Federal Way green
wash · 2009
2 sentences

2025After all, PRA exemptions are recognized through the operation of the PRA, not outside it.”). “[O]ur case law interpreting the PRA injunction statute makes clear that finding an exemption applies under the PRA does not ipso facto support issuing an injunction.” Lyft, 190 Wn.2d at 786 (citing Spokane Police Guild, 112 Wn.2d at 36 ; Soter, 162 Wn.2d at 757 ; Morgan v. City of Federal Way, 166 Wn.2d 747, 756-57 , 20 John Does v. Seattle Police Dep’t et al.

2025After all, PRA exemptions are recognized through the operation of the PRA, not outside it.”). “[O]ur case law interpreting the PRA injunction statute makes clear that finding an exemption applies under the PRA does not ipso facto support issuing an injunction.” Lyft, 190 Wn.2d at 786 (citing Spokane Police Guild, 112 Wn.2d at 36 ; Soter, 162 Wn.2d at 757 ; Morgan v. City of Federal Way, 166 Wn.2d 747, 756-57 , 20 John Does v. Seattle Police Dep’t et al.

32018–2025
Progressive Animal Welfare Society v. University of Washington green
wash · 1994
2 sentences

2025Id.; PAWS, 125 Wn.2d at 257-58 ; Spokane Police Guild, 112 Wn.2d at 36 .

2025No. 102182-8 the exemption at issue is expressly set out in the PRA or incorporated via an ‘other statute’” (citing PAWS, 125 Wn.2d at 258 ; Spokane Police Guild, 112 Wn.2d at 36, 39 )); see also Soter v. Cowles Publ’g Co., 162 Wn.2d 716, 757 , 174 P.3d 60 (2007) (plurality opinion).

22025–2025
SEIU Healthcare 775NW v. Department of Social & Health Services green
washctapp · 2016
2 sentences

2025Id.; SEIU Healthcare, 193 Wn.

2025Id.; SEIU Healthcare, 193 Wn.

22025–2025
BAINBRIDGE POLICE GUILD v. City of Puyallup green
wash · 2011
2 sentences

2025Lyft, 190 Wn.2d at 790-91, 779-80 (if the information is exempt, “then ‘judicial inquiry commences’ with the court applying the PRA injunction standard” (quoting Spokane Police Guild, 112 Wn.2d at 36 )); Bainbridge Island Police Guild v. City of Puyallup, 172 Wn.2d 398, 408 , 259 P.3d 190 (2011) (plurality opinion).

2025Lyft, 190 Wn.2d at 790-91, 779-80 (if the information is exempt, “then ‘judicial inquiry commences’ with the court applying the PRA injunction standard” (quoting Spokane Police Guild, 112 Wn.2d at 36 )); Bainbridge Island Police Guild v. City of Puyallup, 172 Wn.2d 398, 408 , 259 P.3d 190 (2011) (plurality opinion).

22025–2025
Wright v. Department of Social & Health Services green
washctapp · 2013
2 sentences

2014App. 585 , 596 -97, 309 P. 3d 662 ( 2013), review denied, No. 89396 -9 ( Wash. Feb. 6, 2014) ( holding that juvenile records at issue were exempt from disclosure under an " other statute," chaptef 13. 50 RCW, which provides the exclusive means of obtaining juvenile justice and care records, without discussing the PRA injunction standard). 12 No. 44520 -4 -II standard, RCW 42. 56. 540, must also be met.

2014App. 585, 596-97 , 309 P.3d 662 (2013) (holding that juvenile records at issue were exempt from disclosure under an “other statute,” chapter 13.50 RCW, which provides the exclusive means of obtaining juvenile justice and care records, without discussing the PRA injunction standard), review denied, 179 Wn.2d 1021 (2014).

22014–2014
Port of Seattle v. International Longshoremen's & Warehousemen's Union green
wash · 1958
2 sentences

2018Tyler Pipe Indus., 96 Wash.2d at 792 , 638 P.2d 1213 (quoting Port of Seattle v. Int'l Longshoremen's & Warehousemen's Union , 52 Wash.2d 317 , 319, 324 P.2d 1099 (1958) ). ¶ 23 The City counters that the PRA injunction standard applies rather than the UTSA standard because L/R seek to enjoin the City from complying with its duty to disclose records under the PRA.

2018Tyler Pipe Indus., 96 Wash.2d at 792 , 638 P.2d 1213 (quoting Port of Seattle v. Int'l Longshoremen's & Warehousemen's Union , 52 Wash.2d 317 , 319, 324 P.2d 1099 (1958) ). ¶ 23 The City counters that the PRA injunction standard applies rather than the UTSA standard because L/R seek to enjoin the City from complying with its duty to disclose records under the PRA.

12018–2018
Tyler Pipe Industries, Inc. v. Department of Revenue green
wash · 1982
2 sentences

2018Tyler Pipe Indus., 96 Wash.2d at 792 , 638 P.2d 1213 (quoting Port of Seattle v. Int'l Longshoremen's & Warehousemen's Union , 52 Wash.2d 317 , 319, 324 P.2d 1099 (1958) ). ¶ 23 The City counters that the PRA injunction standard applies rather than the UTSA standard because L/R seek to enjoin the City from complying with its duty to disclose records under the PRA.

2018Tyler Pipe Indus., 96 Wash.2d at 792 , 638 P.2d 1213 (quoting Port of Seattle v. Int'l Longshoremen's & Warehousemen's Union , 52 Wash.2d 317 , 319, 324 P.2d 1099 (1958) ). ¶ 23 The City counters that the PRA injunction standard applies rather than the UTSA standard because L/R seek to enjoin the City from complying with its duty to disclose records under the PRA.

12018–2018

Statutes the citing opinions construe

WA § Wash. Rev. Code § 42.56.070 (8) WA § Wash. Rev. Code § 42.56.540 (7) WA § Wash. Rev. Code § 42.56.030 (6) WA § Wash. Rev. Code § 42.56.050 (5) WA § Wash. Rev. Code § 42.56.230 (4) WA § Wash. Rev. Code § 2.06.040 (3) WA § Wash. Rev. Code § 42.56.010 (3) WA § Wash. Rev. Code § 42.56.240 (3) WA § Wash. Rev. Code § 42.56.550 (3)

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.

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