FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON JUNE 12, 2025
IN CLERK’S OFFICE SUPREME COURT, STATE OF WASHINGTON SARAH R. PENDLETON JUNE 12, 2025 SUPREME COURT CLERK
IN THE SUPREME COURT OF THE STATE OF WASHINGTON
JOHN DOE P, JOHN DOE Q, JOHN ) No. 102976-4 DOE R, and JOHN DOE S, as ) individuals and on behalf of others ) similarly situated, ) ) En Banc Petitioners, ) ) v. ) ) Filed: June 12, 2025 THURSTON COUNTY, a municipal ) organization, and its departments ) the THURSTON COUNTY ) PROSECUTING ATTORNEY and ) THURSTON COUNTY SHERIFF, ) ) Respondents, ) ) DONNA ZINK and JEFF ZINK, a ) married couple, ) ) Respondents/Cross ) Petitioners. ) _______________________________)
YU, J. — This case involves a postdismissal challenge to a trial court’s order
permanently sealing the petitioners’ actual names and allowing them to be John Doe P et al. v. Thurston County et al., No. 102976-4
identified by pseudonym in court records. The underlying case is a PRA 1
injunction action, in which the petitioners (John Does P, Q, R, and S) sought to
enjoin Thurston County (County) from releasing unredacted sex offender records
in response to cross petitioner Donna Zink’s PRA request.
Over the course of these proceedings, nearly all of the Does’ PRA
exemption claims have been rejected on the merits, and Zink received most of the
records she requested. The Does ultimately moved for voluntary dismissal but
sought to do so without revealing their identities. The trial court granted the Does’
motion and entered a permanent order to (1) maintain the use of pseudonyms in
court records pertaining to this case and (2) seal a court record (Disclosure
Document) listing the Does’ actual names. As a result, the Does have never been
publicly identified, by name, as the plaintiffs in this case.
For the reasons explained below, we affirm the Court of Appeals in part and
hold that the order sealing the Disclosure Document was an abuse of discretion
because the trial court’s findings are not sufficient to satisfy GR 15 or Seattle
Times Co. v. Ishikawa, 97 Wn.2d 30, 640 P.2d 716 (1982). For similar reasons, the
trial court abused its discretion in allowing the Does to remain in pseudonym, and
we hold the pseudonym issue is not moot. Given our resolution of these issues, we
decline to reach the evidentiary challenges raised in Zink’s cross petition for
1 Public Records Act, ch. 42.56 RCW.
2 John Doe P et al. v. Thurston County et al., No. 102976-4
review. We remand to the trial court with instructions to (1) unseal the Disclosure
Document, (2) use the Does’ actual names in future proceedings and court records
(if any) pertaining to this case, and (3) order that the pseudonyms in the Superior
Court Management Information System (SCOMIS) indices be replaced with the
Does’ actual names.
FACTUAL AND PROCEDURAL BACKGROUND
This case has a lengthy procedural history, including multiple appeals. It is
not necessary to review this history in detail, but a brief overview provides
important context for the issues presented.
A. The Does bring a PRA injunction action in pseudonym and obtain a permanent injunction on summary judgment
In October 2014, Zink made a PRA request for Thurston County’s sex
offender records, including any lists or databases, registration records, victim
impact statements, and evaluations for special sex offender sentencing alternatives
(SSOSAs) and special sex offender disposition alternatives (SSODAs). See RCW
9.94A.670; RCW 13.40.162.
The County notified the sex offenders named in the records, including the
Does, and began preparing its response to Zink’s PRA request. The Does are level
I sex offenders. 2 Does P and Q were convicted of sex offenses as adults; Does R
2 Level I sex offenders are “those classified as the least likely to reoffend.” John Doe A v. Wash. State Patrol, 185 Wn.2d 363, 368, 374 P.3d 63 (2016).
3 John Doe P et al. v. Thurston County et al., No. 102976-4
and S were adjudicated as juveniles. Does P and S both attest they are compliant
with their registration requirements, and Does R and Q have been relieved of the
duty to register.
In January 2015, the Does filed this action seeking to permanently enjoin the
release of unredacted sex offender records in response to Zink’s PRA request. The
Does asserted several claims of exemption based on statutes outside the PRA
governing the dissemination of sex offender records, health care information, and
juvenile records. The Does subsequently moved for a preliminary injunction and
for permission to proceed in pseudonym. In support, they filed declarations
detailing the anticipated harms of being publicly identified as sex offenders, as
well as several trial court orders granting similar relief in other cases.
The trial court granted the Does’ motion to remain in pseudonym
“throughout the pendency of this action.” Clerk’s Papers (CP) at 25. The court
reasoned that pseudonyms were necessary to preserve the Does’ ability to obtain
relief, should they ultimately succeed in their PRA injunction action. However, the
trial court did not conduct an Ishikawa analysis in accordance with article I, section
10 of the Washington Constitution. 3 Instead, the court adopted the Does’ argument
that article I, section 10 is “not triggered” by pseudonymous litigation. Id. at 748.
3 “Justice in all cases shall be administered openly, and without unnecessary delay.”
4 John Doe P et al. v. Thurston County et al., No. 102976-4
The parties subsequently filed cross motions for summary judgment. The
trial court ruled in favor of the Does on all of their PRA exemption claims and
found that the Does had “credibly attest[ed] to the substantial and irreparable harm
to class members if the requested documents were disclosed without redactions.”
Id. at 32. Based on these rulings, the trial court granted the Does’ motion for
summary judgment and permanently enjoined the County from releasing
unredacted records in response to Zink’s PRA request.
B. Nearly all of the Does’ PRA exemption claims are rejected, but the Does are granted permission to remain in pseudonym
This action has been the subject of multiple appeals. Over the course of
appellate proceedings, nearly all of the Does’ PRA exemption claims have been
rejected on the merits.
Zink filed her first appeal after the trial court granted summary judgment to
the Does. While the appeal was pending, this court decided John Doe A v.
Washington State Patrol, which rejected a PRA exemption claim for sex offender
registration records that was materially identical to one of the Does’ claims in this
case. 185 Wn.2d 363, 374 P.3d 63 (2016). Thus, following John Doe A, the Court
of Appeals here reversed in part and held “that the registration records must be
released.” John Doe P v. Thurston County, 199 Wn. App. 280, 283, 399 P.3d 1195
(2017) (Doe I), modified on other grounds on remand, No. 48000-0-II (Wash. Ct.
App. Oct. 2, 2018) (Doe II) (unpublished),
5 John Doe P et al. v. Thurston County et al., No. 102976-4
https://www.courts.wa.gov/opinions/pdf/D2%2048000-0-
II%20Unpublished%20Opinion.pdf. However, the Does’ remaining PRA
exemption claims and the use of pseudonyms were affirmed, and Zink petitioned
for this court’s review.
While the petition for review was pending, this court decided John Doe G v.
Department of Corrections, which rejected a PRA exemption claim for SSOSA
evaluations that the Does had also raised in this case. 190 Wn.2d 185, 410 P.3d
1156 (2018). John Doe G further held, contrary to the trial court in this case, “that
names in pleadings are subject to article I, section 10” and that an order to proceed
in pseudonym “must meet the Ishikawa factors,” as well as GR 15. Id. at 201.
Following John Doe G, the Court of Appeals reversed the order allowing the
Does to proceed in pseudonym and rejected all but one of the Does’ PRA
exemption claims. Doe II, No. 48000-0-II, slip op. at 11. However, the court held
that “unredacted SSODA evaluations are exempt” because “ch. 13.50 RCW is an
‘other statute’ exemption that bars the release of juvenile justice and care records.”
Id. at 7. This holding is not challenged and does not affect our resolution of the
issues presented. Although SSODA evaluations are exempt from the PRA, the
Does acknowledge that all of their actual names (including those adjudicated as
juveniles) appear in publicly available lists of sex offenders, which Zink compiled
using public records obtained through PRA requests. See Letter from Am. C.L.
6 John Doe P et al. v. Thurston County et al., No. 102976-4
Union of Wash. to Wash. Sup. Ct., John Doe P v. Zink, No. 102976-4 (Wash. Feb.
21, 2025) (Letter from Couns.); CP at 34.
On remand in the trial court, the Does moved to remain in pseudonym based
on the declarations they had previously submitted. Alternatively, the Does argued
that John Doe G should not apply “retroactively” to them and sought to voluntarily
dismiss their PRA injunction action without revealing their identities. CP at 678.
The trial court ruled that GR 15 and Ishikawa had been met and entered an order
allowing the Does to remain in pseudonym for one year. However, the order
expressly cautioned that it would be reviewed “periodically,” and the court
required the Does to file a sealed Disclosure Document listing their actual names
“in case it decides in the future that sealing the court record is not appropriate.” Id.
at 149. The trial court also lifted its permanent injunction, ordered the County to
continue processing its response to Zink’s PRA request, and issued a judgment for
costs in favor of Zink with the Does listed as judgment debtors.
Zink appealed the order sealing the Disclosure Document and allowing the
Does to remain in pseudonym. The Court of Appeals affirmed, and Zink did not
seek further review. John Doe P v. Thurston County, No. 56345-2-II (Wash. Ct.
App. July 19, 2022) (Doe III) (unpublished),
https://www.courts.wa.gov/opinions/pdf/D2%2056345-2-
II%20Unpublished%20Opinion.pdf.
7 John Doe P et al. v. Thurston County et al., No. 102976-4
The Does subsequently moved for voluntary dismissal and to permanently
seal their names in court records pertaining to their case by maintaining the use of
pseudonyms and sealing the Disclosure Document indefinitely. In support, the
Does refiled the same declarations supporting their original motion to proceed in
pseudonym, as well as new declarations from each of the Does and Doe R’s
mother, Jane Roe R. Zink opposed the request to remain in pseudonym, arguing
that the Does had not met their burden or, in the alternative, that any new sealing
order should be limited to one year.
The trial court granted the Does’ motion for voluntary dismissal and found
that the Does had “again established compelling privacy and safety concerns and a
serious imminent threat of numerous forms of harm if their names are
revealed . . . that sufficiently outweigh the public interest and the requesters’
interests.” CP at 431. Based on these findings, the court ordered the Does’ actual
names to remain sealed through the use of pseudonyms and the sealing of the
Disclosure Document. The trial court’s order was permanent in duration, “unless
and until there is a subsequent motion” supported by “proof of compelling
circumstances that sealing is no longer necessary.” Id. at 433. Zink moved for
reconsideration, but the court declined her request to set an expiration date for its
order, reasoning that this “would unnecessarily clog the court with hearings that
don’t need to happen.” Rep. of Proc. (Jan. 20, 2023) at 46.
8 John Doe P et al. v. Thurston County et al., No. 102976-4
C. The Court of Appeals reverses the order sealing the Disclosure Document but holds the continued use of pseudonyms is moot
Zink appealed, challenging the trial court’s evidentiary rulings and its order
permanently sealing the Disclosure Document and allowing the Does to remain in
pseudonym. The Court of Appeals reversed in part and held that the order sealing
the Disclosure Document was an abuse of discretion in violation of GR 15. The
court reasoned that “the information the Does sought to protect by filing their
lawsuit—their identities as sex offenders—became publicly available” long ago,
and the Does had failed to “identify privacy or safety concerns specific to their
identities as the plaintiffs in this lawsuit.” John Doe P v. Thurston County, No.
85909-9-I, slip. op. at 6 (Wash. Ct. App. Jan. 29, 2024) (Doe IV) (unpublished)
(emphasis added), https://www.courts.wa.gov/opinions/pdf/859099.pdf. However,
the Court of Appeals declined to reach Zink’s evidentiary challenges and held the
pseudonym issue was “moot” because “Zink has received or will receive the
records she is entitled to, no claims remain to be litigated, and the trial court
dismissed the Does’ lawsuit with prejudice.” Id. at 8 n.12.
The Does and Zink subsequently filed cross petitions for review, which we
granted. The Does, Zink, and the County have all filed supplemental briefs.
ISSUES
A. Is the trial court’s order allowing the permanent use of pseudonyms in
court records pertaining to this case moot?
9 John Doe P et al. v. Thurston County et al., No. 102976-4
B. Did the trial court abuse its discretion in ordering the permanent use
of pseudonyms and permanently sealing the Disclosure Document?
ANALYSIS
Our state constitution requires that “[j]ustice in all cases shall be
administered openly, and without unnecessary delay.” CONST. art. I, § 10. The
open administration of justice presumptively includes public access to the actual
names of litigants. John Doe G, 190 Wn.2d at 201. However, the “right of
access . . . may be outweighed by some competing interest as determined by the
trial court on a case-by-case basis according to the Ishikawa guidelines.” Allied
Daily Newspapers of Wash. v. Eikenberry, 121 Wn.2d 205, 211, 848 P.2d 1258
(1993). Thus, an order allowing a litigant to proceed or remain in pseudonym,
including at the postdismissal stage, must be justified in accordance with both GR
15 and the Ishikawa factors. See John Doe G, 190 Wn.2d at 198-202.
A trial court’s decision granting or denying a motion to seal court records is
reviewed for abuse of discretion. State v. Richardson, 177 Wn.2d 351, 357, 302
P.3d 156 (2013). A trial court abuses its discretion when it relies “on facts
unsupported in the record,” applies “the wrong legal standard,” or “adopts a view
‘that no reasonable person would take.’” State v. Rohrich, 149 Wn.2d 647, 654, 71
P.3d 638 (2003) (quoting State v. Lewis, 115 Wn.2d 294, 298-99, 797 P.2d 1141
(1990)). In determining the applicable legal standard, our review is de novo. In re
10 John Doe P et al. v. Thurston County et al., No. 102976-4
Dependency of M.H.P, 184 Wn.2d 741, 753, 364 P.3d 94 (2015). In this case, the
trial court’s findings are insufficient to satisfy GR 15 and Ishikawa as a matter of
law. Therefore, the trial court abused its discretion in granting the Does’ request to
remain in pseudonym and permanently seal the Disclosure Document.
A. The order allowing the Does to remain in pseudonym is not moot
As a threshold issue, we must determine whether the Does’ continued use of
pseudonyms is a moot issue in this case. An issue is moot if “a court can no longer
provide effective relief.” AURC III, LLC v. Point Ruston Phase II, LLC, 3 Wn.3d
80, 86, 546 P.3d 385 (2024). The Does and Zink correctly agree that the use of
pseudonyms is not moot, and we reverse the Court of Appeals on this issue.
The Court of Appeals held the use of pseudonyms was moot in light of John
Doe A. However, in that case, the use of pseudonyms was moot because the public
records at issue already identified “the names of the parties.” John Doe A, 185
Wn.2d at 385. Because those records would be released, this court was “unable to
offer any further relief.” Id. By contrast, in this case, the court can provide further
effective relief if we reach the merits of the pseudonym issue.
The trial court’s order in this case seals the Does’ actual names through both
the use of pseudonyms and the sealing of the Disclosure Document. These dual
aspects of the order operate independently to shield the Does’ actual names from
public view. Thus, regardless of whether Zink obtains the Does’ real names by
11 John Doe P et al. v. Thurston County et al., No. 102976-4
unsealing the Disclosure Document, the “public’s interest in the open
administration of justice” continues to be impeded by the use of pseudonyms in
court records, such as SCOMIS indices. Hundtofte v. Encarnación, 181 Wn.2d 1,
4, 330 P.3d 168 (2014) (plurality opinion) (emphasis added). Therefore, we hold
the Does’ continued use of pseudonyms is not moot.
B. The trial court abused its discretion in permanently sealing the Does’ actual names contrary to GR 15 and Ishikawa
On the merits, we must determine whether the trial court abused its
discretion in permanently sealing the Does’ identities at this postdismissal stage of
the proceedings. As noted above, the Court of Appeals held the trial court abused
its discretion, contrary to GR 15, but it declined to conduct “the more rigorous
Ishikawa analysis.” Doe IV, No. 85909-9-I, slip op. at 7 n.10. Because GR 15
embodies the principles set forth in Ishikawa, we address both on review. On the
merits, we hold the trial court abused its discretion because its findings are
insufficient to satisfy GR 15 or Ishikawa as a matter of law.
1. The trial court abused its discretion in ruling that the Does met their burden pursuant to GR 15
“[W]e must start with the presumption of openness when determining
whether a court record may be sealed from the public.” Encarnación, 181 Wn.2d
at 7. Therefore, an order sealing a court record must sufficiently identify
“compelling privacy or safety concerns that outweigh the public interest in access
12 John Doe P et al. v. Thurston County et al., No. 102976-4
to the court record.” GR 15(c)(2). In this case, the trial court’s order allowing the
Does to remain permanently in pseudonym does not contain findings sufficient to
satisfy GR 15 and was therefore an abuse of discretion.
As discussed above, while the Does’ PRA injunction action was pending, the
trial court entered several preliminary orders allowing the Does to proceed in
pseudonym. These orders preserved the Does’ “ability to seek relief” in their PRA
injunction action; in other words, because the Does’ PRA injunction action sought
to shield their identities as sex offenders, revealing the Does’ identities in litigation
would “eviscerate” their claims. CP at 25; see also id. at 148. The trial court’s
preliminary orders also found the Does faced “a potential for a serious imminent
threat of harm” based on their declarations, which describe fears of “being
identified as a sex offender” due to “personal experiences of being ‘ostracized’”
and knowledge of others who “were regularly harassed and beat up because people
found out they were sex offenders.” Id. at 148, 164, 814.
However, over the course of this litigation, these preliminary findings
allowing the Does to bring their action in pseudonym have lost their force. When
each of the Does’ identities as sex offenders became publicly available, the harms
of publicly revealing that information became moot. Similarly, when the Does
voluntarily dismissed their PRA injunction action, their ability to seek relief ended.
Thus, the trial court’s findings allowing the use of pseudonyms while the action
13 John Doe P et al. v. Thurston County et al., No. 102976-4
was pending are not sufficient, as a matter of law, to justify the continued use of
pseudonyms following dismissal.
Yet, the trial court’s order allowing the Does to remain in pseudonym
postdismissal does not sufficiently articulate new compelling privacy or safety
concerns. Instead, the trial court noted that the “Does have been allowed to
proceed in pseudonym since the start of the case in 2015” and found that the Does
had “again established compelling privacy and safety concerns and a serious
imminent threat of numerous forms of harm if their names are revealed . . . that
sufficiently outweigh the public interest and the requesters’ interests.” Id. at 430-
31. This conclusory finding is insufficient as a matter of law. See John Doe G,
190 Wn.2d at 202.
On review, the Does argue that they articulated sufficient privacy and safety
concerns to remain in pseudonym postdismissal, pointing to their declarations
expressing concerns of being identified “in association with this lawsuit.” CP at
809. Yet, the substance of these concerns derives from “the label ‘sex offender’”
and “how sex offenders get targeted by vigilantes,” not participation in a PRA
action. Id. at 809, 820. As noted above, the Does have confirmed that their actual
names now appear on publicly available lists of sex offenders compiled by Zink. 4
4 Jane Roe R’s name does not appear on the lists; she is Doe R’s mother, and she filed a declaration in support of sealing the Does’ actual names. However, she is not a party to this
14 John Doe P et al. v. Thurston County et al., No. 102976-4
Letter from Couns., supra. Further, it is undisputed Zink compiled these lists using
public records she obtained through PRA requests. See id.; CP at 34. Thus, “by
participating in this case, the John Does are not subject to any disclosures that
should otherwise be exempt.” John Doe G, 190 Wn.2d at 200.
The trial court’s findings are insufficient to justify the continued use of
pseudonyms and sealing of the Disclosure Document following dismissal of the
Does’ action. Therefore, the trial court abused its discretion contrary to GR 15.
2. The trial court abused its discretion in ruling that the Does met their burden in accordance with Ishikawa
GR 15 is a court rule, but it derives from the principles of Ishikawa and
article I, section 10’s “‘separate, clear and specific provision [that] entitles the
public . . . to openly administered justice.’” Ishikawa, 97 Wn.2d at 36 (quoting
Cohen v. Everett City Council, 85 Wn.2d 385, 388, 535 P.2d 801 (1975)).
Therefore, in addition to complying with GR 15, an order permitting a party to
proceed in pseudonym must satisfy the Ishikawa factors:
(1) identify the need to seal court records, (2) allow anyone present in the courtroom an opportunity to object, (3) determine whether the requested method is the least restrictive means of protecting the interests threatened, (4) weigh the competing interests and consider alternative methods, and (5) issue an order no broader than necessary.
action and she does not articulate any reason to shield her identity independently of her son’s. Therefore, we do not conduct an independent analysis as to Jane Roe R.
15 John Doe P et al. v. Thurston County et al., No. 102976-4
John Doe G, 190 Wn.2d at 199 (citing Ishikawa, 97 Wn.2d at 37-39). Each
Ishikawa factor “‘should be articulated in [the court’s] findings and conclusions,
which should be as specific as possible rather than conclusory.’” Id. at 202
(alteration in original) (quoting Ishikawa, 97 Wn.2d at 38). Here, the trial court’s
order summarily addresses each of the Ishikawa factors, but its findings are
conclusory and not sufficiently supported by the record.
The first Ishikawa factor requires a showing that public access to the Does’
identities in connection with this action “must be restricted to prevent a serious and
imminent threat to an important interest.” 97 Wn.2d at 37. This “‘is more specific,
concrete, certain, and definite than’ the ‘compelling privacy or safety concerns’
required by GR 15(c)(2).” M.H.P., 184 Wn.2d at 765 (quoting State v. Waldon,
148 Wn. App. 952, 962-63, 202 P.3d 325 (2009)). However, as discussed above,
the harms specifically articulated by the Does’ declarations are based on their
identities as sex offenders, not PRA plaintiffs. Therefore, it was an abuse of
discretion to rely on these concerns in support of the first Ishikawa factor.
The Does also articulate broader concerns that if “pseudonym reversal” is
permitted on appeal, it will “chill[ ] sensitive parties from engaging in meritorious
litigation.” Pet. for Rev. at 18, 1. However, as noted above, the trial court’s
preliminary orders allowing the Does to proceed in pseudonym were expressly
time limited. Indeed, as discussed below, orders sealing presumptively open court
16 John Doe P et al. v. Thurston County et al., No. 102976-4
records are generally subject to “durational limits.” Richardson, 177 Wn.2d at
362. Moreover, although we recognize the vital role that pseudonymous litigation
plays in the development of our laws and the recognition of our rights, “the
public’s involvement plays a significant role” in the legal system, as well. John
Doe G, 190 Wn.2d at 201.
It has long been established that Washington courts are constitutionally
prohibited from restricting the public’s access to court records, absent “a serious
and imminent threat to an important interest,” which must be articulated “as
specifically as possible.” Ishikawa, 97 Wn.2d at 37; see also Encarnación, 181
Wn.2d at 9. Here, the Does “do not have a legitimate privacy interest to protect” in
their identities as sex offenders or as litigants. John Doe G, 190 Wn.2d at 200.
Furthermore, this action was not brought to vindicate a constitutional right; the
Does’ underlying PRA exemption claims are statutory. 5 Thus, the Does’ concerns
about protecting pseudonymous litigation in general, though wholeheartedly
shared by this court, are insufficient to establish a specific need to shield their
identities in this case. We hold the trial court abused its discretion in ruling the
first Ishikawa factor was met.
5 Contra John Does 1 v. Seattle Police Dep’t, 4 Wn.3d 343, 354, 563 P.3d 1037 (2025) (plaintiffs “asserted disclosure would violate their constitutional rights”).
17 John Doe P et al. v. Thurston County et al., No. 102976-4
Before entering its order, the trial court offered those present in the
courtroom an opportunity to object, satisfying the second Ishikawa factor. 97
Wn.2d at 38. The trial court also addressed the third and fourth Ishikawa factors,
and ruled that allowing the Does to remain in pseudonym and sealing the
Disclosure Document would be “the least restrictive means” and the only “viable
alternative” that would be “effective in protecting the interests threatened.” CP at
432; Ishikawa, 97 Wn.2d at 38. However, this was premised on the ruling that the
first Ishikawa factor was met, which was an abuse of discretion. Where sealing is
not justified, determining the least restrictive means is unnecessary.
Finally, the fifth Ishikawa factor requires that any order “‘must be no
broader in its application or duration than necessary to serve its purpose.’”
Ishikawa, 97 Wn.2d at 39 (quoting Federated Publ’ns v. Kurtz, 94 Wn.2d 51, 64,
615 P.2d 440 (1980)). “If the order involves sealing of records, it shall apply for a
specific time period with a burden on the proponent to come before the court at a
time specified to justify continued sealing.” Id. As we have previously
recognized, “[t]his factor requires the trial court to consider durational limits” on
orders to continue sealing “presumptively open” court records, such as the order
permitting pseudonymous litigation in this case. Richardson, 177 Wn.2d at 362,
360. However, the trial court declined to set an expiration date for its order,
18 John Doe P et al. v. Thurston County et al., No. 102976-4
effectively granting the Does a permanent right to remain in pseudonym. This was
legal error and an abuse of discretion.
CONCLUSION
We affirm the Court of Appeals in holding that the trial court abused its
discretion by sealing the Disclosure Document because its findings are insufficient
to satisfy GR 15. We further hold that the order allowing the Does to remain in
pseudonym is not moot and was also an abuse of discretion contrary to GR 15. In
addition, we hold that the trial court abused its discretion in ruling that the
Ishikawa factors had been satisfied as to both the use of pseudonyms and the
sealing of the Disclosure Document. Given our resolution of these issues, we
decline to reach the evidentiary issues raised in Zink’s cross petition for review.
Thus, we affirm the Court of Appeals in part, reverse in part, and remand to
the trial court with instructions to (1) unseal the Disclosure Document, (2) use the
Does’ actual names in future proceedings and court records (if any) pertaining to
this case, and (3) order that the Does’ pseudonyms in the SCOMIS indices be
replaced with their actual names.
19 John Doe P et al. v. Thurston County et al., No. 102976-4
WE CONCUR:
Lee, J.P.T.