Graham v. Bar Association

Certiorari was granted by this court to review an order quashing a subpoena duces tecum sought by the *625State Auditor, petitioner herein, as part of his effort to obtain records with which he could conduct a postaudit of the respondent Washington State Bar Association. The trial court concluded the applicable statutes authorized petitioner to conduct the audit but that he was prohibited from doing so by the separation of powers doctrine. We hold the bar association is not a state agency or state department within the meaning of the applicable statutes, that only excess receipts from the…