Fortgang v. Woodland Park Zoo

¶1 Petitioner Alyne Fortgang filed a request for documents concerning the elephants at the Woodland Park Zoo (Zoo). She filed that request under the Public Records Act (PRA), chapter 42.56 RCW, which requires every government “agency” to make records “available for [public] inspection and copying.” RCW 42.56.010, .040. But she filed it with the Woodland Park Zoo Society (WPZS), the private nonprofit that runs the Zoo. WPZS argues that the PRA can never reach the records of such a private entity.

¶2 We disagree. The PRA is “a strongly-worded mandate for open government,” Rental Hous. Ass’n of…