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Washington Prisoners Have No Right to Inspect Records Under Public Records Act
Prisoners who request records from the Washington Department of Corrections (DOC) under the Public Records Act (PRA) do not have a right to inspect records without cost, the Court of Appeals, Division II held in a corrected ruling entered on March 4, 2011. The appellate court’s opinion joins a similar, earlier decision reached by the Court of Appeals, Division III.
DOC prisoners Derek E. Gronquist and Byron A. Mustard requested that they be allowed to inspect various records maintained by the DOC. The PRA allows requesters to ask for inspection instead of copies of records, but the DOC only allows prisoners to inspect their central file and medical file. Gronquist and Mustard wanted to inspect other records.
The DOC offered to provide Gronquist and Mustard with copies of the requested records, but they refused to pay for the copies, insisting that they be allowed to inspect the records instead. The DOC declined to permit inspection.
Gronquist and Mustard then filed suit, arguing that the DOC’s refusal to allow them to inspect the requested records without cost violated the PRA. The trial court entered judgment in favor of the DOC, and Gronquist and Mustard appealed.
Citing the decision of the Court of Appeals, Division III in Sappenfield v. Department of Corrections, 127 Wash.App. 83, 110 P.3d 808 (Wash.App. Div. 3 2005), review denied, the Court of Appeals, Division II held that the PRA did not require the DOC to honor Gronquist and Mustard’s request for inspection.
“The unique nature of prisoner requests for PRA disclosures,” the appellate court wrote, “entitled [the DOC] to adopt reasonable rules to protect both the records and its essential agency functions.”
The Court of Appeals, Division II noted that the DOC did not deny the prisoners’ “requests or fail to identify withheld documents.” Rather, Gronquist and Mustard “simply refused to pay for the copies.”
The judgment of the trial court was accordingly affirmed. See: Gronquist v. Department of Corrections, 159 Wash.App. 576, 247 P.3d 436 (Wash.App. Div. 2 2011), review denied.
DOC prisoners Derek E. Gronquist and Byron A. Mustard requested that they be allowed to inspect various records maintained by the DOC. The PRA allows requesters to ask for inspection instead of copies of records, but the DOC only allows prisoners to inspect their central file and medical file. Gronquist and Mustard wanted to inspect other records.
The DOC offered to provide Gronquist and Mustard with copies of the requested records, but they refused to pay for the copies, insisting that they be allowed to inspect the records instead. The DOC declined to permit inspection.
Gronquist and Mustard then filed suit, arguing that the DOC’s refusal to allow them to inspect the requested records without cost violated the PRA. The trial court entered judgment in favor of the DOC, and Gronquist and Mustard appealed.
Citing the decision of the Court of Appeals, Division III in Sappenfield v. Department of Corrections, 127 Wash.App. 83, 110 P.3d 808 (Wash.App. Div. 3 2005), review denied, the Court of Appeals, Division II held that the PRA did not require the DOC to honor Gronquist and Mustard’s request for inspection.
“The unique nature of prisoner requests for PRA disclosures,” the appellate court wrote, “entitled [the DOC] to adopt reasonable rules to protect both the records and its essential agency functions.”
The Court of Appeals, Division II noted that the DOC did not deny the prisoners’ “requests or fail to identify withheld documents.” Rather, Gronquist and Mustard “simply refused to pay for the copies.”
The judgment of the trial court was accordingly affirmed. See: Gronquist v. Department of Corrections, 159 Wash.App. 576, 247 P.3d 436 (Wash.App. Div. 2 2011), review denied.
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Related legal case
Gronquist v. Department of Corrections
| Year | 2011 |
|---|---|
| Cite | 159 Wash.App. 576, 247 P.3d 436 (Wash.App. Div. 2 2011) |
| Level | State Court of Appeals |
| Conclusion | Bench Verdict |
| Injunction Status | Granted |