Gronquist v. Department of Corrections

¶1 Derek E. Gronquist appeals several superior court orders and findings entered in his Public Records Act (PRA)1 lawsuit. He argues that the superior court erred in (1) limiting the penalty period of the Department of Corrections’ (DOC) PRA violation and awarding a penalty amount that was too small and (2) concluding that the surveillance video recordings he requested on August 9, 2007, were exempt from disclosure under the PRA. We hold that RCW 42.56.565(1) bars an award of PRA penalties to Gronquist because (1) he was serving a criminal sentence in a correctional facility when he made his…