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Search for Records Under Washington PRA Held Inadequate
The Division III Court of Appeals for the State of Washington has reversed a grant of summary judgment for the County of Spokane in a suit under the Washington Public Records Act (PRA).
Neighborhood Alliance sent a PRA request to the county for a copy of an office space seating chart and other related documents. The county disclosed the seating chart ultimately, but failed to turn over an electronic information log related to when the chart was created.
The Court of Appeals held that the county had failed to conduct an adequate search for the information log because the county had only looked on one computer, when the log could have possibly been found on another computer. The county “did not search the computer [that] was us[ed] when the seating chart was created,” the court wrote.
Accordingly, summary judgment for the county on the adequacy of its search for the information log was reversed.
See: Neighborhood Alliance v. County of Spokane, 153 Wash.App. 241, 224 P.3d 775.
Neighborhood Alliance sent a PRA request to the county for a copy of an office space seating chart and other related documents. The county disclosed the seating chart ultimately, but failed to turn over an electronic information log related to when the chart was created.
The Court of Appeals held that the county had failed to conduct an adequate search for the information log because the county had only looked on one computer, when the log could have possibly been found on another computer. The county “did not search the computer [that] was us[ed] when the seating chart was created,” the court wrote.
Accordingly, summary judgment for the county on the adequacy of its search for the information log was reversed.
See: Neighborhood Alliance v. County of Spokane, 153 Wash.App. 241, 224 P.3d 775.
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Related legal case
Neighborhood Alliance v. County of Spokane
| Year | 2010 |
|---|---|
| Cite | 153 Wash.App. 241, 224 P.3d 775 |
| Level | State Court of Appeals |
| Injunction Status | N/A |