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

Wash. Rev. Code § 42.56.550 (2026)

Judicial review of agency actions

✓ current as of May 2026
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(1) Upon the motion of any person having been denied an opportunity to inspect or copy a public record by an agency, the superior court in the county in which a record is maintained may require the responsible agency to show cause why it has refused to allow inspection or copying of a specific public record or class of records. The burden of proof shall be on the agency to establish that refusal to permit public inspection and copying is in accordance with a statute that exempts or prohibits disclosure in whole or in part of specific information or records.
(2) Upon the motion of any person who believes that an agency has not made a reasonable estimate of the time that the agency requires to respond to a public record request or a reasonable estimate of the charges to produce copies of public records, the superior court in the county in which a record is maintained may require the responsible agency to show that the estimate it provided is reasonable. The burden of proof shall be on the agency to show that the estimate it provided is reasonable.
(3) Judicial review of all agency actions taken or challenged under RCW 42.56.030 through 42.56.520 shall be de novo. Courts shall take into account the policy of this chapter that free and open examination of public records is in the public interest, even though such examination may cause inconvenience or embarrassment to public officials or others. Courts may examine any record in camera in any proceeding brought under this section. The court may conduct a hearing based solely on affidavits.
(4) Any person who prevails against an agency in any action in the courts seeking the right to inspect or copy any public record or the right to receive a response to a public record request within a reasonable amount of time shall be awarded all costs, including reasonable attorney fees, incurred in connection with such legal action. In addition, 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.
(5) For actions under this section against counties, the venue provisions of RCW 36.01.050 apply.
(6) Actions under this section must be filed within one year of the agency's claim of exemption or the last production of a record on a partial or installment basis.
[ 2017 c 304 s 5; 2011 c 273 s 1. Prior: 2005 c 483 s 5; 2005 c 274 s 288; 1992 c 139 s 8; 1987 c 403 s 5; 1975 1st ex.s. c 294 s 20; 1973 c 1 s 34 (Initiative Measure No. 276, approved November 7, 1972). Formerly RCW 42.17.340.]

Notes:

Intent—Severability—1987 c 403: See notes following RCW 42.56.050.
Application of chapter 300, Laws of 2011: See note following RCW 42.56.565.
Notes of Decisions
Cited in 363 cases (75 in the last 5 years), 2007–2026 · leading case: Neighborhood All. of Spokane v. Spokane, 261 P.3d 119 (Wash. 2011).
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Neighborhood All. of Spokane v. Spokane, 261 P.3d 119 (Wash. 2011). · cites it 46× “RCW 42.56.550 provides a speedy remedy for a requester to obtain a court hearing on whether an agency has violated the PRA.”
Rental Hous. Ass'n v. City of Des Moines, 199 P.3d 393 (Wash. 2009). · cites it 27× “RCW 42.56.550(1). Administrative inconvenience or difficulty does not excuse strict compliance with the PRA.”
Rental Hous. Ass'n v. City of Des Moines, 165 Wash. 2d 525 (Wash. 2009). · cites it 26× “The burden of proof is on the agency to establish that any refusal to permit public inspection and copying is in accordance with a statute that exempts or prohibits disclosure in whole or in part.”
Belenski v. Jefferson Cnty., 378 P.3d 176 (Wash. 2016). · cites it 22× “See RCW 42.56.550. Our standard of review is de novo.”
West v. State Dept. of Nat. Resources, 258 P.3d 78 (Wash. Ct. App. 2011). · cites it 35× “Based on this issue, we reverse and remand for the trial court to consider an attorney fee and penalty award under former RCW 42.56.550(4) (2008) [4] in light of the DNR's violation.”
Sanders v. State, 240 P.3d 120 (Wash. 2010). · cites it 10× “RCW 42.56.550(3). [13] Because these documents were in the record, summaries of them would be permissible under ER 1006 (allowing summaries of voluminous documents if the originals are also made available).”
Sanders v. State, 169 Wash. 2d 827 (Wash. 2010). · cites it 9× “RCW 42.56.550(4) 10 (emphasis added). The “brief explanation” requirement is one aspect of the “response [s]” referred to in this provision.”
Soter v. Cowles Publ'g Co., 162 Wash. 2d 716 (Wash. 2007). · cites it 9× “520 shall be de novo, and a court may examine the records in camera to determine whether disclosure is proper. RCW 42.”
Johnson v. State Dept. of Corr., 265 P.3d 216 (Wash. Ct. App. 2011). · cites it 24× “550(1) provides: Upon the motion of any person having been denied an opportunity to inspect or copy a public record by an agency, the superior court in the county in which a record is maintained may require the responsible agency to show cause why it has refused to allow…”
Soter v. Cowles Pub. Co., 174 P.3d 60 (Wash. 2007). · cites it 8× “520 shall be de novo, and a court may examine the records in camera to determine whether disclosure is proper. RCW 42.”
Doe v. Washington State Patrol, 374 P.3d 63 (Wash. 2016). · cites it 4× “RCW 42.56.550(3); Spokane Police Guild, 112 Wn.”
West v. Thurston Cnty., 275 P.3d 1200 (Wash. Ct. App. 2012). · cites it 6× “RCW 42.56.550(1). ¶35 The PRA requires the agency to respond to a PRA request within five business days, however, only if the request seeks “public records.”
Show all 363 citing cases →
— Wash. Rev. Code § 42.56.550(1) — 113 cases
Neighborhood All. of Spokane v. Spokane, 261 P.3d 119 (Wash. 2011). “RCW 42.56.550 provides a speedy remedy for a requester to obtain a court hearing on whether an agency has violated the PRA.”
Soter v. Cowles Publ'g Co., 162 Wash. 2d 716 (Wash. 2007). “520 shall be de novo, and a court may examine the records in camera to determine whether disclosure is proper. RCW 42.”
Soter v. Cowles Pub. Co., 174 P.3d 60 (Wash. 2007). “520 shall be de novo, and a court may examine the records in camera to determine whether disclosure is proper. RCW 42.”
Gendler v. Batiste, 274 P.3d 346 (Wash. 2012).
Burt v. Dep't of Corr., 168 Wash. 2d 828 (Wash. 2010).
— Wash. Rev. Code § 42.56.550(2) — 21 cases
Neighborhood All. of Spokane v. Spokane, 261 P.3d 119 (Wash. 2011). “RCW 42.56.550 provides a speedy remedy for a requester to obtain a court hearing on whether an agency has violated the PRA.”
Freedom Found. v. Dshs, 445 P.3d 971 (Wash. Ct. App. 2019).
Soter v. Cowles Publ'g Co., 162 Wash. 2d 716 (Wash. 2007). “520 shall be de novo, and a court may examine the records in camera to determine whether disclosure is proper. RCW 42.”
Soter v. Cowles Pub. Co., 174 P.3d 60 (Wash. 2007). “520 shall be de novo, and a court may examine the records in camera to determine whether disclosure is proper. RCW 42.”
Yousoufian v. Off. of Ron Sims, 229 P.3d 735 (Wash. 2010).
— Wash. Rev. Code § 42.56.550(3) — 214 cases
Neighborhood All. of Spokane v. Spokane, 261 P.3d 119 (Wash. 2011). “RCW 42.56.550 provides a speedy remedy for a requester to obtain a court hearing on whether an agency has violated the PRA.”
Gendler v. Batiste, 274 P.3d 346 (Wash. 2012).
Soter v. Cowles Publ'g Co., 162 Wash. 2d 716 (Wash. 2007). “520 shall be de novo, and a court may examine the records in camera to determine whether disclosure is proper. RCW 42.”
Soter v. Cowles Pub. Co., 174 P.3d 60 (Wash. 2007). “520 shall be de novo, and a court may examine the records in camera to determine whether disclosure is proper. RCW 42.”
Sargent v. Seattle Police Dept., 314 P.3d 1093 (Wash. 2013).
— Wash. Rev. Code § 42.56.550(4) — 230 cases
West v. State Dept. of Nat. Resources, 258 P.3d 78 (Wash. Ct. App. 2011). “Based on this issue, we reverse and remand for the trial court to consider an attorney fee and penalty award under former RCW 42.56.550(4) (2008) [4] in light of the DNR's violation.”
Neighborhood All. of Spokane v. Spokane, 261 P.3d 119 (Wash. 2011). “RCW 42.56.550 provides a speedy remedy for a requester to obtain a court hearing on whether an agency has violated the PRA.”
Sanders v. State, 240 P.3d 120 (Wash. 2010). “RCW 42.56.550(3). [13] Because these documents were in the record, summaries of them would be permissible under ER 1006 (allowing summaries of voluminous documents if the originals are also made available).”
Sanders v. State, 169 Wash. 2d 827 (Wash. 2010). “RCW 42.56.550(4) 10 (emphasis added). The “brief explanation” requirement is one aspect of the “response [s]” referred to in this provision.”
West v. Thurston Cnty., 275 P.3d 1200 (Wash. Ct. App. 2012). “RCW 42.56.550(1). ¶35 The PRA requires the agency to respond to a PRA request within five business days, however, only if the request seeks “public records.”
— Wash. Rev. Code § 42.56.550(6) — 41 cases
Rental Hous. Ass'n v. City of Des Moines, 199 P.3d 393 (Wash. 2009). “RCW 42.56.550(1). Administrative inconvenience or difficulty does not excuse strict compliance with the PRA.”
Rental Hous. Ass'n v. City of Des Moines, 165 Wash. 2d 525 (Wash. 2009). “The burden of proof is on the agency to establish that any refusal to permit public inspection and copying is in accordance with a statute that exempts or prohibits disclosure in whole or in part.”
Belenski v. Jefferson Cnty., 378 P.3d 176 (Wash. 2016). “See RCW 42.56.550. Our standard of review is de novo.”
Johnson v. State Dept. of Corr., 265 P.3d 216 (Wash. Ct. App. 2011). “550(1) provides: Upon the motion of any person having been denied an opportunity to inspect or copy a public record by an agency, the superior court in the county in which a record is maintained may require the responsible agency to show cause why it has refused to allow…”
Greenhalgh v. Dep't of Corr., 282 P.3d 1175 (Wash. Ct. App. 2012).
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