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

Wash. Rev. Code § 42.56.904 (2026)

✓ current as of May 2026
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It is the intent of the legislature to clarify that no reasonable construction of chapter 42.56 RCW has ever allowed attorney invoices to be withheld in their entirety by any public entity in a request for documents under that chapter. It is further the intent of the legislature that specific descriptions of work performed be redacted only if they would reveal an attorney's mental impressions, actual legal advice, theories, or opinions, or are otherwise exempt under chapter 391, Laws of 2007 or other laws, with the burden upon the public entity to justify each redaction and narrowly construe any exception to full disclosure. The legislature intends to clarify that the public's interest in open, accountable government includes an accounting of any expenditure of public resources, including through liability insurance, upon private legal counsel or private consultants.
[ 2007 c 391 s 1.]
Notes of Decisions
Cited in 11 cases (1 in the last 5 years), 2008–2023 · leading case: Yakima Cnty. v. Yakima Herald-Repub., 170 Wash. 2d 775 (Wash. 2011).
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Yakima Cnty. v. Yakima Herald-Repub., 170 Wash. 2d 775 (Wash. 2011). · cites it 18× “¶16 In its request, the Herald-Republic cited the 2007 amendment to RCW 42.56.904, stating that the amendment clarified that the “ ‘public’s interest in open, accountable government includes an accounting of any expenditures of public resources .”
Yakima v. Yakima Herald-Repub., 246 P.3d 768 (Wash. 2011). · cites it 18× “¶ 16 In its request, the Herald-Republic cited the 2007 amendment to RCW 42.56.904, stating that the amendment clarified that the "`public's interest in open, accountable government includes an accounting of any expenditure of public resources [.”
West v. Thurston Cnty., 275 P.3d 1200 (Wash. Ct. App. 2012). · cites it 3× “We reasoned, RCW 42.56.904 was expressly intended to clarify the Public Records Act’s applicability to records of public funds expended on private legal counsel.”
West v. Thurston Cnty., 144 Wash. App. 573 (Wash. Ct. App. 2008). · cites it 6× “5 ¶19 Soon after an Olympia newspaper requested the same attorney fee invoices, the 2007 legislature enacted RCW 42.56.904, which provides as follows: It is the intent of the legislature to clarify that no reasonable construction of chapter 42.”
West v. Thurston Cnty., 183 P.3d 346 (Wash. Ct. App. 2008). · cites it 6× “[5] ¶ 19 Soon after an Olympia newspaper requested the same attorney fee invoices, the 2007 legislature enacted RCW 42.56.904, which provides as follows: It is the intent of the legislature to clarify that no reasonable construction of chapter 42.”
Asotin Cnty. v. Richard Eggleston, 432 P.3d 1235 (Wash. Ct. App. 2019). · cites it 3× “” CP at 29, 32 (boldface omitted) (quoting RCW 42.56.904). He stated, “Mr. Eggleston does not object to an in camera 3 No.”
Dep't of Soc. & Health Servs. v. Parvin, 326 P.3d 832 (Wash. Ct. App. 2014). · cites it 2× “565 , we held that attorney billing records did not warrant post-trial sealing to protect the defendant’s right to a fair trial.”
San Juan Cnty., V. Wa Coalition For Open Gov't (Wash. Ct. App. 2023). · cites it 10× “” The court denied WCOG’s counterclaim and dismissed the matter with prejudice.”
Franklin Cnty. Sheriff's Off. v. Parmelee, 253 P.3d 1131 (Wash. Ct. App. 2011). “3d 768 (2011), the court held RCW 42.56.904 (relating to the release of attorney invoices) applies to documents held by a public agency, not “judicial documents held by the judiciary.”
In Re Dep. Of: M.h.p.(11/11/08), P. Parvin & L. Bramlett, Res. v. State, D.s.h.s. (Wash. Ct. App. 2014). · cites it 2× “at 565 , we held that attorney billing records did not warrant post-trial sealing to protect the defendant's right to a fair trial.”
Franklin Cty. Sheriff's Off. v. Parmelee, 253 P.3d 1131 (Wash. Ct. App. 2011). “3d 768 (2011), the court held RCW 42.56.904 (relating to the release of attorney invoices) applies to documents held by a public agency not judicial documents held by the judiciary.”
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