Brian Green, V Department Of Corrections

CourtCourt of Appeals of Washington
DecidedNovember 10, 2025
Docket86878-1
StatusUnpublished

This text of Brian Green, V Department Of Corrections (Brian Green, V Department Of Corrections) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brian Green, V Department Of Corrections, (Wash. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

BRIAN GREEN and CONNOR GREEN, No. 86878-1-I Appellants, (Consolidated with No. 87312-1-I) v. DIVISION ONE STATE OF WASHINGTON DEPARTMENT OF CORRECTIONS, UNPUBLISHED OPINION

Respondent.

COBURN, J. — Brian and Connor Green appeal from the dismissal of their

respective actions against the Department of Corrections (DOC) for violation of the

Public Records Act, chapter 42.56 RCW. The Greens assert that the surveillance video

footage they requested was not exempt from public disclosure under RCW

42.56.240(1). On the record presented, the Greens do not demonstrate any error.

Accordingly, we affirm the decisions of the trial court.

FACTS

Brian and Connor Green each submitted a public records request to DOC for

“Any and all records of any and all video and/or audio recordings made on 19 July 2023

in and/or around the DOC Office located at 6135 Martin Way E suite a, Lacey, WA

98503.” DOC responded to both requests informing the Greens that it did not possess

any audio recordings and that it was withholding all video per RCW 42.56.240(1) and 86878-1/2

RCW 42.56.420(2).

The Greens separately filed suit against DOC for violation of the Public Records

Act, alleging that DOC had unlawfully withheld the requested video. DOC argued

otherwise, asserting that the videos constituted “specific intelligence information”

exempt from disclosure under RCW 42.56.240(1) as well as security information

concerning a correctional facility exempt from disclosure under RCW 42.56.420(2). In

support of its arguments, DOC submitted the declaration of Mac Pevey, assistant

secretary for the community corrections division of DOC. Pevey explained that not all of

DOC’s cameras possessed the same recording capability:

Some cameras have recording capabilities and others do not. Some camera stations (camera housings such as boxes and bubble housings) do not contain cameras at all. Some cameras have poor resolution or may be out of service. Some cameras have very narrow fields of view, while others have wide fields of view. Some are PTZ (pan, tilt, & zoom) which have powerful abilities to capture fine detail at long distances. Some are controlled by the person monitoring the camera. Some pan a wide field automatically. Some cameras are so well hidden, they are not suspected to be present.

Pevey further explained that surveillance, or at least the appearance of surveillance,

was a powerful deterrent to criminal behavior, including acts of violence and carrying of

contraband. Providing surveillance footage to the public would, in Pevey’s opinion,

leave DOC offices and staff vulnerable to security breaches, an especially pressing

concern in light of recent arson attempts, vandalism of vehicles, and smashed exterior

windows.

Connor Green filed a motion to strike Pevey’s declaration and impose CR 11

sanctions on DOC, asserting that the declaration was plagiarized and that Pevey had no

actual personal knowledge of any of the facts he attested to. Connor also filed a motion

2 86878-1/3

to strike all references to the Pevey declaration from DOC’s response, as well as all

statements he believed to be prejudicial rhetoric. Brian Green also moved to strike

Pevey’s declaration but only did so after the trial court dismissed his complaint.

In both cases, the trial court considered the parties’ motions and concluded that

the requested records were exempt from disclosure under RCW 42.56.240(1), though

not under RCW 42.56.420(2). The trial court found that the surveillance video

constituted specific intelligence information and concluded that nondisclosure of the

video footage is essential for effective law enforcement, including the enforcement of

community custody conditions. Brian Green moved for reconsideration, which the trial

court denied.

The trial court denied Connor’s motion to strike portions of DOC’s response and

his motion to strike Pevey’s declaration and to impose CR 11 sanctions, finding there

was no basis for either motion. The trial court denied Brian’s motion to strike as moot.

The Greens each appealed the trial court’s dismissal of their respective actions.

We consolidated the appeals for review.

DISCUSSION

Standard of Review

Judicial review of agency actions taken or challenged under the PRA is de

novo. Forbes v. City of Gold Bar, 171 Wn. App. 857, 863, 288 P.3d 384 (2012) (quoting

RCW 42.56.550(3)). An appellate court reviews a trial court’s PRA determination de

novo “where the record consists only of affidavits, memoranda of law, and other

documentary evidence” because it then “stands in the same position as the trial

court.” Progressive Animal Welfare Soc’y v. Univ. of Wash., 125 Wn.2d 243, 252, 884

3 86878-1/4

P.2d 592 (1994).

An agency withholding public records bears the burden of demonstrating that the

claimed exemption applies. Prison Legal News, Inc. v. Dep’t of Corr., 154 Wn.2d 628,

636, 115 P.3d 316 (2005). “In determining whether the PDA requires disclosure, we

must liberally construe its public records provisions and narrowly construe its

exemptions.” Lindeman v. Kelso Sch. Dist. No. 458, 162 Wn.2d 196, 201, 172 P.3d 329

(2007).

The Greens assert that DOC violated the PRA when it withheld the video footage

they requested because the footage is not exempt. DOC withheld the requested video

footage from the Greens claiming an exemption under RCW 42.56.240(1). This statute

provides that the following records are exempt from public disclosure:

[s]pecific intelligence information and specific investigative records compiled by investigative, law enforcement, and penology agencies, and state agencies vested with the responsibility to discipline members of any profession, the nondisclosure of which is essential to effective law enforcement or for the protection of any person's right to privacy[.]

RCW 42.56.240(1).

We have previously analyzed this exemption in three parts: (1) whether the

records constitute “specific intelligence information” or “specific investigative records,”

(2) whether the records were compiled by an investigative, law enforcement, or

penology agency, and (3) whether nondisclosure of the records “is essential to effective

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