Wash. Rev. Code » Title 42 · Chapter 42.56
Revised Code of Washington

Wash. Rev. Code § 42.56.280 (2026)

Preliminary drafts, notes, recommendations, intra-agency memorandums

✓ current as of May 2026
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Preliminary drafts, notes, recommendations, and intra-agency memorandums in which opinions are expressed or policies formulated or recommended are exempt under this chapter, except that a specific record is not exempt when publicly cited by an agency in connection with any agency action.
[ 2005 c 274 s 408.]
Notes of Decisions
Cited in 14 cases (3 in the last 5 years), 2008–2025 · leading case: Freedom Found. v. Gregoire, 310 P.3d 1252 (Wash. 2013).
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Freedom Found. v. Gregoire, 310 P.3d 1252 (Wash. 2013). · cites it 3× “Our courts are already familiar with the in camera review process mandated by the PRA to determine whether an exemption applies. RCW 42.”
Rental Hous. Ass'n v. City of Des Moines, 165 Wash. 2d 525 (Wash. 2009). “310(1)(i) (2003) (now codified at RCW 42.56.280), the deliberative process exemption, and former RCW 42.”
Rental Hous. Ass'n v. City of Des Moines, 199 P.3d 393 (Wash. 2009). “310(1)(i) (2003) (now codified at RCW 42.56.280), the deliberative process exemption, and former RCW 42.”
West v. Port of Olympia, 146 Wash. App. 108 (Wash. Ct. App. 2008). “RCW 42.56.280 11 provides: Preliminary drafts, notes, recommendations, and intra-agency memorandums in which opinions are expressed or policies formulated or recommended are exempt under this chapter, except that a specific record is not exempt when publicly cited by an agency…”
West v. Port of Olympia, 192 P.3d 926 (Wash. Ct. App. 2008). “RCW 42.56.280 [11] provides: Preliminary drafts, notes, recommendations, and intra-agency memorandums in which opinions are expressed or policies formulated or recommended are exempt under this chapter, except that a specific record is not exempt when publicly cited by an agency…”
Ameriquest Mortg. Co. v. Attorney Gen., 148 Wash. App. 145 (Wash. Ct. App. 2009). “240, the deliberative process exemption, RCW 42.56.280, or the attorney-client privilege and attorney work product exemptions, RCW 5.”
Ameriquest Mortg. Co. v. State Atty. Gen., 199 P.3d 468 (Wash. Ct. App. 2009). “240, the deliberative process exemption, RCW 42.56.280, or the attorney-client privilege and attorney work product exemptions, RCW 5.”
Citizen Action Def. Fund v. Off. of Fin. Mgmt. (Wash. 2025). · cites it 9× “280, applies to the initial offers for collective bargaining agreements (CBAs) once the tentative CBAs have been signed by the parties and submitted to the Office of Financial Management (OFM) director, but have not been signed by the governor or funded by the legislature.…”
Richard Eggleston v. Asotin Cnty. (Wash. Ct. App. 2017). · cites it 4× “The County responded on May 16, 2012, claiming the April Plans were exempt from disclosure under RCW 42.56.280. The County reasoned that this exemption applied because the April Plans were preliminary 1 Apart from the page Mr.”
Citizen Action Def. Funds, V. Wa State Fin. Mgmt. (Wash. Ct. App. 2024). · cites it 4× “OFM denied the request, stating that the records were exempt from disclosure under the deliberative process exemption statute, RCW 42.56.280. CADF filed a lawsuit against OFM in December 2022, alleging a violation of the PRA.”
Amanda Thornewell, V. Seattle Sch. Dist. No. 1 (Wash. Ct. App. 2024). · cites it 3× “” Roxane O’Connor, assistant legal counsel and public records officer at the District, suggested to Enlow he connect with Robert Veliz, the investigator assigned to the OSCR investigation, and she expressed concern about whether the investigation was closed and whether any of…”
Jamie Wallin v. City Of Everett (Wash. Ct. App. 2016). · cites it 2× “In the letter, the City asserted an exemption applied to the "decline notice" records under RCW 42.56.280. RCW 42.56.280 exempts "[preliminary drafts, notes, recommendations, and intra-agency memorandums in which opinions are expressed or policies formulated or recommended.”
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