Nissen v. Pierce County

¶1 Glenda Nissen appeals the superior court’s CR 12(b)(6) dismissal of her Public Records Act (PRA)1 action against Pierce County and the Pierce County Prosecutor’s Office (County); she also appeals several other related superior court orders. At issue is whether a government employee’s private cellular telephone call log records and text messages are “public records” subject to disclosure under the PRA. We hold that (1) call logs for a government official’s private cellular phone constitute “public records” only with regard to the calls that relate to government business and only if these…