West v. Port of Olympia

¶1 Arthur West appeals the trial court’s dismissal of his Public Records Act (PRA), ch. 42.56 RCW, claim against the Port of Olympia. West’s claim is based on the Port’s redactions of a Port employee’s name, job title, job duties, and other identifying details from an investigative report relating to unsubstantiated allegations of governmental misconduct made against that employee. The Port made the redactions under the exemption in former RCW 42.56.230(2) (2011) for personal information that would violate an employee’s right to privacy.

¶2 We assume without deciding that the employee’s…