J.M.I. v. State

CourtWashington Supreme Court
DecidedApril 30, 2026
Docket104,167-5
StatusPublished

This text of J.M.I. v. State (J.M.I. v. State) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J.M.I. v. State, (Wash. 2026).

Opinion

FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON IN CLERK’S OFFICE APRIL 30, 2026 SUPREME COURT, STATE OF WASHINGTON APRIL 30, 2026 SARAH R. PENDLETON SUPREME COURT CLERK

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

J.M.I., No. 104167-5 Respondent, v. STATE OF WASHINGTON, En Banc Petitioner. Filed: April 30, 2026

S.P., a minor, by BRUCE A. WOLF, her guardian ad litem, Respondent, v. STATE OF WASHINGTON, Petitioner.

TACI MARSON, by and through Northstar Case Management, her Guardian and Conservator, Respondent, v. STATE OF WASHINGTON, DEPARTMENT OF SOCIAL & HEALTH SERVICES, DEPARTMENT OF CHILDREN, YOUTH & FAMILIES, Petitioner. J.M.I. v. State, No. 104167-5

DAREL MAXFIELD, as guardian for F.H., a minor; N.H., individually, Respondents, v. STATE OF WASHINGTON, DEPARTMENT of SOCIAL and HEALTH SERVICES; DEPARTMENT of CHILDREN, YOUTH, & FAMILIES; DEPARTMENT OF CHILD PROTECTIVE SERVICES, governmental entities; and DOES 1-5, individuals or entities, Petitioner.

MUNGIA, J.—The State is required to protect and promote the welfare of foster

children and investigate complaints of abuse. Ch. 74.13 RCW. The plaintiffs 1 allege that

the State failed to carry out its duty and, as a result, each of them was sexually or

physically abused.

The plaintiffs have filed lawsuits against the State. In each lawsuit, the plaintiffs

seek discovery from the State that not only includes their case files but also other

documents relevant to proving that the State breached the duty it owed to each of them.

The State does not dispute that under CR 26, the plaintiffs would be entitled to

these documents. Indeed, up until these cases, the State complied with these types of

1 We use the term plaintiffs throughout this opinion to refer collectively to J.M.I., S.P., Taci Marson, F.H., and N.H., the respondents in this action. 2 J.M.I. v. State, No. 104167-5

discovery requests so long as protective orders limiting their use were in place. However,

the State now takes the position that these documents are protected by a statutory

privilege and are not discoverable. The trial courts, in these consolidated cases for

appeal, ruled in the plaintiffs’ favor, ordering the State to produce the requested records.

The State sought direct review in this court, which was granted.

We hold that the types of documents plaintiffs are seeking here are privileged

under RCW 74.04.060(1)(a). However, we further hold that RCW 74.04.060(1)’s

statutory exception applies in these cases, allowing the plaintiffs to obtain the requested

discovery. We also hold that RCW 13.50.100’s confidentiality and nondisclosure

requirements do not prevent the disclosure of the requested documents. 2

Accordingly, we affirm the trial courts’ orders compelling the State to comply

with the plaintiffs’ discovery requests.

I FORMER FOSTER CHILDREN BROUGHT NEGLIGENCE SUITS AGAINST THE STATE FOR FAILING TO PROTECT THEM FROM ABUSE IN FOSTER CARE. THEY SOUGHT CHILD WELFARE RECORDS TO SUPPORT THEIR CLAIMS, AND THE TRIAL COURTS ORDERED THE RECORDS PRODUCED

J.M.I., S.P., Taci Marson, F.H., and N.H. are former foster children who each sued

the State, alleging that the State negligently placed them in foster homes where they were

abused and that it failed to adequately investigate reports of abuse. In their lawsuits, the

2 Because we find that the statutory privilege does not apply and that the plaintiffs are entitled to discover the information under RCW 13.50.100, we do not address the plaintiffs’ other arguments involving estoppel and constitutional claims. 3 J.M.I. v. State, No. 104167-5

plaintiffs propounded discovery to the State, seeking Department of Children, Youth, and

Families (DCYF) records that sought the following categories of information:

• Information the State used to remove the children from their biological parents;

• Information the State used to vet and license the foster homes; and

• Reports of abuse the State received about those foster homes.

They requested the following records:

• Their own child welfare records;

• Records relating to biological family members;

• Records relating to any allegations received or investigations conducted by the

State regarding their foster parents and the children in their care;

• Records relating to their foster parents, from the time they were licensed to the

present;

• The identity of and records for every dependent child ever placed in the care of the

same foster parents; and

• Investigation files concerning other state-licensed foster homes controlled by the

State.

In prior lawsuits, when similarly situated plaintiffs propounded similar discovery

to the State, the State agreed that the information was discoverable and produced the

requested records subject to a protective order. The State has now changed its position.

The State asserts that the requested information is privileged and thus not subject to

discovery. The State moved for protective orders asserting that RCW 74.04.060(1)(a) and 4 J.M.I. v. State, No. 104167-5

RCW 13.50.100 barred it from producing nonparty child welfare records. The trial courts

denied the State’s motions, finding the statutes did not prevent the production of the records.

The trial courts ordered production of the requested records, requiring redaction of

employee personnel information, Social Security numbers, financial information, health

care information, and attorney-client and work product privileged documents.

The courts also limited how the plaintiffs could use the information. The courts

ordered that the parties could not use the records for any purpose other than the present

litigation, prohibiting their dissemination beyond what was reasonably needed for the case.

In J.M.I.’s and S.P.’s cases, the trial courts ordered that any copies or summaries of the

documents must be returned to counsel at the conclusion of the proceedings. The courts

required a party that filed, discussed, or referenced confidential material to consider filing a

motion to seal or redact pursuant to GR 15. The orders specified that the court would hold a

hearing outside the presence of the jury to determine the admissibility of the confidential

evidence prior to introducing or otherwise disclosing the existence of such evidence at trial.

The State sought discretionary review of the discovery orders. This court granted

review of the cases of J.M.I., S.P., Marson, and Maxfield, consolidated the cases, 3 and

stayed the orders to compel pending our review. 4 This court stayed several other similar

cases pending this decision. 5

3 See Am. Comm’r’s Ruling Granting Mot. to Transfer (Wash. July 30, 2025). 4 Notation ruling, Marson v. Dep’t of Soc. & Health Servs., No. 60059-5-II (Wash. Ct. App. Oct. 15, 2024); Notation ruling, Maxfield v. Dep’t of Soc. & Health Servs., No. 60162-1-II (Wash. Ct. App. Nov. 19, 2024). 5 Am. Comm’r’s Ruling, supra.

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