West v. Gregoire

¶1 Arthur West appeals the trial court’s dismissal, following show cause proceedings under former RCW 42.56.550 (2005),1 of his complaint alleging that then Governor Christine Gregoire violated the Public Records Act (PRA), chapter 42.56 RCW, by refusing to produce numerous records under a claim of executive privilege. West initially argued that the trial court erred in recognizing an executive privilege as a PRA exemption. However, our Supreme Court resolved this issue in Freedom Foundation v. Gregoire, 178 Wn.2d 686, 310 P.3d 1252 (2013), holding that a qualified executive communications…