Jeffrey Thurman v. Cowles Company

CourtCourt of Appeals of Washington
DecidedJanuary 11, 2024
Docket38991-0
StatusPublished

This text of Jeffrey Thurman v. Cowles Company (Jeffrey Thurman v. Cowles Company) 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
Jeffrey Thurman v. Cowles Company, (Wash. Ct. App. 2024).

Opinion

FILED JANUARY 11, 2024 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

JEFFREY THURMAN, ) No. 38991-0-III ) Respondent, ) ) v. ) PUBLISHED OPINION ) COWLES COMPANY, ) ) Appellant. )

LAWRENCE-BERREY, A.C.J. — The Uniform Public Expression Protection Act

(UPEPA or the Act), chapter 4.105 RCW, provides an expedited process for parties

seeking dismissal of causes of action thought to target activity protected by the First

Amendment to the United States Constitution. The process envisions a defendant, not

later than 60 days after being served with a pleading asserting a covered cause of action,

filing a special motion for expedited relief.

This opinion addresses (1) whether the UPEPA applies to causes of action pending

on the Act’s effective date, (2) whether service of an amended complaint restarts the 60-

day period for filing the special motion, (3) inconsistency between rules adopted by our

Supreme Court and some procedural rules in the UPEPA, and (4) constitutional as- No. 38991-0-III Thurman v. Cowles

applied challenges to the UPEPA. We conclude (1) the UPEPA applies to causes of

action asserted on or after the Act’s effective date, (2) service of an amended pleading

restarts the 60-day period with respect to new claims, (3) to the extent the UPEPA’s rules

of court procedure are inconsistent with those adopted by our Supreme Court, the latter

must be given precedent, and (4) the constitutional as-applied challenges fail. We affirm

in part and reverse in part.

FACTS

On June 13, 2019, Cowles Publishing Company, d/b/a, the Spokesman-Review,

published an article about Jeffrey Thurman. The article’s headline read: “Spokane

County sheriff’s sergeant fired for racial slur, sexual harassment, talk of killing black

people.” Clerk’s Papers (CP) at 514. Under a picture of Mr. Thurman and his police dog,

the caption read in part: “[Jeff Thurman] was fired on June 13, 2019, after an internal

investigation found he allegedly spoke of killing black people and sexually harassed a

female deputy on his helicopter crew. He denies the allegations and is suing Sheriff

Ozzie Knezovich for defamation.” CP at 514. The body of the article included details of

the alleged wrongdoing, as well as how the sheriff’s department investigated the alleged

wrongdoing. In large part, the information reported came from an interview with the

sheriff and the sheriff’s press conference.

2 No. 38991-0-III Thurman v. Cowles

On June 14, 2021, Mr. Thurman filed a complaint against Cowles Company, the

parent company of Cowles Publishing Company, alleging defamation and invasion of

privacy by false light. In the complaint, Thurman alleged that Cowles and the sheriff had

engaged in an agreement . . . whereby Cowles would not investigate the facts underlying the Sheriff’s upcoming defamatory announcement, and it would be given an “exclusive” on publication in exchange.

CP at 6. Thurman further alleged that the June 13, 2019 article, as well as articles

published on June 18, 2019, July 2, 2019, June 21, 2020, and August 5, 2020, contained

defamatory statements.

After obtaining leave of court, on December 3, 2021, Jeffrey Thurman filed an

amended complaint.1 The amended complaint alleged additional factual allegations to the

defamation cause of action, did not allege the invasion of privacy cause of action, and

alleged a Consumer Protection Act (CPA), chapter 19.86 RCW, cause of action.

On December 29, 2021, Cowles sent Mr. Thurman a letter notifying him of its

intent to seek dismissal of the lawsuit. On January 21, 2022, Cowles filed a special

1 The court’s November 19, 2021 order granting motion to amend required Mr. Thurman to serve the amended complaint on Cowles. There is no declaration of service in the record attesting that this was done. For purposes of this appeal, we presume that Mr. Thurman complied with the court’s order and effected service on or about December 3, 2021, the date Mr. Thurman filed his amended complaint.

3 No. 38991-0-III Thurman v. Cowles

motion for expedited relief, seeking to dismiss both the defamation and the CPA causes

of action.

The trial court partially granted Cowles’ motion. It concluded the UPEPA did not

apply to Mr. Thurman’s defamation cause of action because it was asserted before the

effective date of the new law. The court did apply the UPEPA to the CPA cause of action

and dismissed it as violative of Cowles’ First Amendment rights. The court declined

Cowles’ request for reasonable attorney fees, reasoning that each party had partially

prevailed in their motions.

Cowles timely appealed the partial denial of its motion for expedited relief.2 Mr.

Thurman cross appealed.

ANALYSIS

OVERVIEW OF THE EXPEDITED DISMISSAL PROCESS

The legislature passed the UPEPA to safeguard traditional First Amendment rights

guaranteed to the public and the press. See RCW 4.105.901. The Act creates a special

procedure to quickly resolve cases that target the “[e]xercise of the right of freedom of

speech or of the press, the right to assemble or petition, or the right of association,

2 RCW 4.105.080 grants a moving party who is denied expedited relief, in whole or in part, the right of direct appeal.

4 No. 38991-0-III Thurman v. Cowles

guaranteed by the United States Constitution or Washington state Constitution, on a

matter of public concern.” RCW 4.105.010(2)(c). It does this by allowing parties to

bring a special motion for expedited relief “[n]ot later than sixty days after a party is

served with a complaint, cross-claim, counterclaim, third-party claim, or other pleading

that asserts a cause of action to which this chapter applies . . . to dismiss the cause of

action or part of the cause of action.” RCW 4.105.020(2).

Upon the filing of the motion, all other proceedings—including pending discovery

and other motions—are stayed. RCW 4.105.030(1)(a). The record for the special motion

is limited to “the pleadings, the motion, any reply or response to the motion, and any

evidence that could be considered in ruling on a motion for summary judgment under

superior court civil rule 56.” RCW 4.105.050.

The court must dismiss the cause of action or part of the cause of action if three

conditions are met: (1) the moving party establishes under RCW 4.105.010(2) that the

chapter applies, (2) the responding party fails to establish under RCW 4.105.010(3) that

the chapter does not apply, and (3) the responding party fails to establish a prima facie

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