Wade's Eastside Gun Shop, Inc. v. Department of Labor & Industries

¶1 This appeal arises from an action brought by the Seattle Times against the Department of Labor and Industries (L&I) for withholding nonexempt public records in violation of the Public Records Act (PRA), chapter 42.56 RCW. It presents two novel questions about the PRA, and additional fact-specific questions. First, we must determine whether a trial court has discretion to calculate penalties for nondisclosure of public records on a per page basis by defining the term “record” to include a single page. Second, we must determine whether L&I investigations qualify for the categorical…