Nissen v. Pierce County

¶1 Five years ago, we concluded that the Public Records Act (PRA), chapter 42.56 RCW, applied to a record stored on a personal computer, recognizing that “[i]f government employees could circumvent the PRA by using their home computers for government business, the PRA could be drastically undermined.” O’Neill v. City of Shoreline, 170 Wn.2d 138, 150, 240 P.3d 1149 (2010). Today, we consider if the PRA similarly applies when a public employee uses a private cell phone to conduct government business. We hold that text messages sent and received by a public employee in the employee’s official…