Jeremy Conklin, V. University Of Washington School Of Medicine

CourtCourt of Appeals of Washington
DecidedJanuary 3, 2023
Docket83200-0
StatusUnpublished

This text of Jeremy Conklin, V. University Of Washington School Of Medicine (Jeremy Conklin, V. University Of Washington School Of Medicine) 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
Jeremy Conklin, V. University Of Washington School Of Medicine, (Wash. Ct. App. 2023).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

JEREMY CONKLIN, DO, an individual, No. 83200-0-I Appellant, DIVISION ONE v. UNPUBLISHED OPINION UNIVERSITY OF WASHINGTON SCHOOL OF MEDICINE, a Washington public educational institution; UNIVERSITY OF WASHINGTON MEDICINE, a Washington public health system; and UNIVERSITY OF WASHINGTON MEDICAL CENTER, a Washington public hospital,

Respondents.

COBURN, J. — Dr. Jeremy Conklin, personally and through his attorneys,

made four separate Public Records Act (PRA) requests to the University of

Washington (UW) mostly related to its surgical fellowship program. Conklin

contends that UW violated the PRA by providing unreasonable response

estimates, delaying release of records, and conducting an inadequate search to

provide responsive records. Because UW did not conduct an adequate search

and did not provide some responsive documents until after UW considered the

request closed, we reverse the trial court’s denial of claims related to that request

and award attorney fees. We remand for the trial court to determine the amount

Citations and pin cites are based on the Westlaw online version of the cited material No. 83200-0-I/2

of attorney fees and costs on appeal and below, and to proceed with the penalty

phase of trial as well as reconsider Conklin’s request for an in camera review.

We otherwise affirm the trial court in denying Conklin’s remaining PRA claims.

FACTS

Conklin is an osteopathic surgeon with a doctor of osteopathic medicine

degree. In 2017, he applied but was not accepted to the UW’s congenital cardiac

surgery fellowship program. UW School of Medicine (SoM) participates in a

fellowship “match” system operated by the Congenital Cardiac Surgery

Fellowship Committee of the Thoracic Surgery Directors Association (TSDA).

Over a period of about two years, he and his attorneys submitted to UW four

separate records requests as Conklin pursued claims against UW and others in

federal court, including a claim under the PRA.

UW’s Public Records Request Process

UW’s Office of Public Records and Open Meetings (OPR) is the

institutional office at UW that is responsible for managing responses to public

records requests. In January 2021, OPR had nine employees who helped

manage responses to PRA requests. OPR also worked with many UW

employees in other departments to collect and review documents in response to

public records requests. OPR does not prioritize, dedicate extra resources to, or

otherwise give preferential treatment to a requester that sues UW.

UW receives a high volume of public records requests, and OPR manages

responses while considering the essential functions of the university. In 2019,

OPR received 932 PRA requests, and OPR staff reviewed approximately 3.2

2 No. 83200-0-I/3

million pages. In 2020, OPR received 831 PRA requests, and OPR staff

reviewed approximately 1.3 million pages. As of January 1, 2021, OPR had 320

open requests and 1,424,924 pages in queue to be reviewed with many more

documents in the process of being gathered and transferred to OPR by divisions

and colleges throughout UW.

To gather responsive documents, OPR identifies the colleges, schools,

and divisions at UW that potentially have responsive records, notifies a point of

contact, and asks for feedback on how long it will take to gather responsive

documents. There are approximately 50 colleges, schools, and divisions at UW

that OPR manages. OPR takes the feedback it receives from colleges, schools,

and divisions with potentially responsive records on the time needed to gather

those records and provides estimates to requesters on the length of time it will

take to further respond to their requests. The colleges, schools, and divisions

gather documents responsive to public records requests and submit them to

OPR to review for any applicable exemptions.

OPR then reviews the records and determines whether the record is

wholly releasable or partially exempt from release, in which case redactions are

applied to portions of the record and marked with codes referencing the specific

applicable exemption. If OPR decides the record is wholly exempt, OPR creates

a log of those documents.

When OPR completes its review, it releases responsive records to the

requester, including those that are partially releasable along with a cover letter

explaining any exemptions applied, and, if applicable, a log of wholly exempt

3 No. 83200-0-I/4

records. For requests for records that take a long time to respond to completely

and/or include a large volume of records, OPR will make interim releases of

records to requesters on a rolling basis as the review of records is completed.

If a request for public records seeks multiple categories of documents,

OPR still refers to it as a single request and processes the review and release of

records from that request collectively, closing the request only when responding

to all components is complete. If OPR receives multiple separate requests

submitted by the same requester at different times, OPR processes the requests

in the order received, prioritizing its review of records responsive to the earliest

request before moving to the subsequent requests. OPR considers the

requester the individual who made the public records request even if they may be

making the request on behalf of someone else.

The Public Records Requests

A. First Request: PR-2017-00920

On November 16, 2017, Conklin’s attorney at the time, Kristi Favard,

requested the following records from UW, which identified this request as PR-

2017-00920 (PR-920):

- all agreements between UW Medical Center and the Thoracic Surgery Director’s Association and/or American Board of Thoracic Surgery;

- all Medicare funding information, grants, agreements, etc. regarding UW Medical Center’s Medicare grants for residencies and fellowships;

- all documents regarding any osteopathic physician application (individual or in general) to any residency or fellowship at UW Medical Center for the past 10 years, including but not limited to applications, correspondence, inter office emails or memos, etc.;

4 No. 83200-0-I/5

- all documents regarding Dr. Jeremy Conklin’s applications to the UW Medical [C]enter for residency/fellowship;

- all documents regarding RCW 70.41.235 from 1995 to present;

- all documents regarding osteopathic physicians as residents/fellows at UW Medical Center, including any lists of all residents and fellows and their professional titles (OD [v.] MD), selected over the past 10 years.

Tisa Escobar, a public records compliance officer at OPR, acknowledged

receipt of the request that same day and estimated that UW would respond to the

request by December 18. As of that day, OPR had 182 open requests and over

750,000 pages of records awaiting review. Escobar, who had worked in OPR

since before the first request was submitted in 2017, described PR-920 as one of

the broadest requests she had ever managed.

She then contacted UW Medicine, including SoM, to gather responsive

records. On November 17, SoM received the request from OPR. On November

27, Courtney Ng, the records manager in the Dean’s Office for SoM, sent initial

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hearst Corp. v. Hoppe
580 P.2d 246 (Washington Supreme Court, 1978)
Overlake Fund v. City of Bellevue
810 P.2d 507 (Court of Appeals of Washington, 1991)
NEIGHBORHOOD ALLIANCE OF SPOKANE v. Spokane
261 P.3d 119 (Washington Supreme Court, 2011)
Arkison v. Ethan Allen, Inc.
160 P.3d 13 (Washington Supreme Court, 2007)
RENTAL HOUSING ASS'N v. City of Des Moines
199 P.3d 393 (Washington Supreme Court, 2009)
Zink v. City of Mesa
166 P.3d 738 (Court of Appeals of Washington, 2007)
PROSECUTING ATTY'S GUILD v. Kitsap County
231 P.3d 219 (Court of Appeals of Washington, 2010)
Conant v. State
84 P.2d 378 (Washington Supreme Court, 1938)
Theodore Roosevelt Hikel, Jr. v. City Of Lynnwood
389 P.3d 677 (Court of Appeals of Washington, 2016)
Rebecca A. Rufin, Appellant, v. the City of Seattle, Respondent
398 P.3d 1237 (Court of Appeals of Washington, 2017)
Freedom Foundation v. Dshs
445 P.3d 971 (Court of Appeals of Washington, 2019)
Progressive Animal Welfare Society v. University of Washington
884 P.2d 592 (Washington Supreme Court, 1994)
Arkison v. Ethan Allen, Inc.
160 Wash. 2d 535 (Washington Supreme Court, 2007)
Rental Housing Ass'n v. City of Des Moines
165 Wash. 2d 525 (Washington Supreme Court, 2009)
Resident Action Council v. Seattle Housing Authority
327 P.3d 600 (Washington Supreme Court, 2013)
Wade's Eastside Gun Shop, Inc. v. Department of Labor & Industries
372 P.3d 97 (Washington Supreme Court, 2016)
Zink v. City of Mesa
140 Wash. App. 328 (Court of Appeals of Washington, 2007)
Kitsap County Prosecuting Attorney's Guild v. Kitsap County
156 Wash. App. 110 (Court of Appeals of Washington, 2010)
State v. Kipp
286 P.3d 68 (Court of Appeals of Washington, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Jeremy Conklin, V. University Of Washington School Of Medicine, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeremy-conklin-v-university-of-washington-school-of-medicine-washctapp-2023.