John Doe 1-15 v. Cowlitz County Sheriff's Office

CourtCourt of Appeals of Washington
DecidedMarch 30, 2021
Docket52845-2
StatusUnpublished

This text of John Doe 1-15 v. Cowlitz County Sheriff's Office (John Doe 1-15 v. Cowlitz County Sheriff's Office) 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.

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John Doe 1-15 v. Cowlitz County Sheriff's Office, (Wash. Ct. App. 2021).

Opinion

Filed Washington State Court of Appeals Division Two

March 30, 2021 IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II JOHN DOE 1-15, No. 52845-2-II

Appellants,

v.

COWLITZ COUNTY SHERIFF’S OFFICE, UNPUBLISHED OPINION

Respondent.

WORSWICK, J. — John Doe 1-15 sued to enjoin the release of their level one sex offender

records under the Public Records Act (PRA). Chapter 42.56 RCW. The John Does argued that

the requested records were exempt from disclosure as being specific intelligence information or

specific investigative information, the release of which would violate their privacy rights, and

that the records were not in the public interest and the record release would irreparably damage

them. The trial court determined that no exemption applied and ordered that the records be

released, but stayed its order and certified interlocutory appeal. We hold that no PRA exemption

applies. Consequently, we affirm.

FACTS

John Doe 1-15 are level one sex offenders.1 Curtis Hart submitted a public records

request to the Cowlitz County Sheriff’s Office (CCSO) seeking level one sex offender records

1 Level one sex offenders are those classified as the least likely to reoffend. Doe ex rel. Roe v. Washington State Patrol, 185 Wn.2d 363, 368, 374 P.3d 63, 65 (2016). RCW 4.24.550(6)(b). No. 52845-2-II

under the PRA.2 Hart asked for names, dates of birth, addresses, photographs, dates, and

descriptions of offense summary records of all level one sex offenders. Determining that no

exemption applied to the release of the requested records, the CCSO notified the John Does that

their records had been requested and that it intended to fulfill the request absent a court order.

The John Does filed a complaint in superior court seeking declaratory and injunctive

relief, and a motion for an ex parte restraining order to enjoin the CCSO from releasing the

requested records to Hart. The trial court restrained the CCSO from releasing the requested

records to Hart until it held a substantive hearing on the matter.

At that hearing, the John Does argued that the requested records were exempt under the

investigative records exemption, RCW 42.56.240,3 and RCW 42.56.050.4 The John Does also

argued that release of the requested records would not clearly be in the public interest and their

release would substantially and irreparably damage them, and that the court should enjoin their

release under RCW 42.56.540.5 The John Does further argued that the court should consider

2 The record does not contain Hart’s actual PRA request or the date the request was submitted. 3 RCW 42.56.240 prohibits the release of “specific intelligence information and specific investigative records compiled by investigative, law enforcement, and penology agencies, . . . the nondisclosure of which is essential to effective law enforcement or for the protection of any person’s right to privacy.” 4 RCW 42.56.050 states that an invasion or a violation of a right to privacy as referred to in chapter 42.56 RCW only occurs when disclosure of information about a person “(1) Would be highly offensive to a reasonable person, and (2) is not of legitimate concern to the public.” 5 The trial court can enjoin the release of requested information under the PRA when the public disclosure of that information “would clearly not be in the public interest and would substantially and irreparably damage any person, or would substantially and irreparably damage vital governmental functions.” RCW 42.56.540.

2 No. 52845-2-II

Hart’s motivations for obtaining the requested records when determining whether the requested

records are exempt from disclosure under the PRA.

The John Does included affidavits and exhibits claiming that Hart had a history of

engaging in harassment and was a member of the self-styled “Punisher Squad,” which described

itself on social media as “a group of concerned citizens (Radical Child Advocates) that bring

sexual predators to light.” Clerk’s Papers (CP) at 8. They boast that they “publicly shame [sex

offenders] for sport.” CP at 8. Hart had previously been restrained under a lifetime no contact

order due to his harassing behavior against a person whom he believed was a child sexual

predator.

The CCSO responded that, as a law enforcement agency, they were in the best position to

determine whether the records were covered by the investigative records exemption, and that this

exemption did not apply because the records were not investigatory in nature from their

perspective. The CCSO stated that because the nondisclosure of information sought by the John

Does was not “essential to effective law enforcement,” it did not meet the exemption for specific

intelligence information. Verbatim Report of Proceedings at 26.

The court found that (1) Hart was “likely to misuse the information in childish, immature,

and offensive ways that would likely be harmful” to the John Does, (2) Hart was likely to repeat

the conduct that gave rise to his lifetime order of no contact for harassment if the requested

records were released, and (3) the John Does had credible and understandable fear of Hart. CP at

73. Notwithstanding those findings, the court concluded that no exemption applied to the

requested records, and “absent some additional legal authority[,] [the court had] insufficient

guidance as how to consider the motivation of the requester” to enjoin the release of the

3 No. 52845-2-II

requested records under RCW 42.56.540. CP at 74. The trial court denied injunctive relief,

certified its order for interlocutory appeal under RAP 2.4, and stayed its order pending resolution

of the appeal.6

The John Does appeal the trial court’s order denying their injunctive relief.

ANALYSIS

The John Does argue that the trial court erred by not enjoining release of the requested

records. They argue that the specific investigative or intelligence information records

exemption, RCW 42.56.240, applies to their case because level one sex offender information is

intelligence information and nondisclosure is necessary to protect their right to privacy. The

John Does also argue that the trial court erred by not considering Hart’s motivations for his PRA

request in determining whether the exemption applied. The John Does argue that the release of

the requested information violates their right to privacy because it would cause substantial and

irreparable damage and would not clearly be in the public interest. The John Does also argue

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