Barfield v. City of Seattle

In these consolidated cases we review two pretrial discovery orders involving Seattle Police Department Internal Investigation Files (SPDIIF). At issue is whether plaintiffs may obtain discovery of SPDIIF involving prior complaints against the officers in actions alleging tortious conduct by police officers; negligent hiring, retention, and discipline; and 42 U.S.C. § 1983 civil rights violations.

In Barfield v. Seattle the following facts are pertinent. Plaintiffs David Barfield and Garry Biney were riding a motorcycle in April 1980. Police Officer T. C. Dillon, in plain clothes and an…