King County v. Sorensen

CourtWashington Supreme Court
DecidedSeptember 8, 2022
Docket100,731-1
StatusPublished

This text of King County v. Sorensen (King County v. Sorensen) 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
King County v. Sorensen, (Wash. 2022).

Opinion

NOTICE: SLIP OPINION (not the court’s final written decision)

The opinion that begins on the next page is a slip opinion. Slip opinions are the written opinions that are originally filed by the court. A slip opinion is not necessarily the court’s final written decision. Slip opinions can be changed by subsequent court orders. For example, a court may issue an order making substantive changes to a slip opinion or publishing for precedential purposes a previously “unpublished” opinion. Additionally, nonsubstantive edits (for style, grammar, citation, format, punctuation, etc.) are made before the opinions that have precedential value are published in the official reports of court decisions: the Washington Reports 2d and the Washington Appellate Reports. An opinion in the official reports replaces the slip opinion as the official opinion of the court. The slip opinion that begins on the next page is for a published opinion, and it has since been revised for publication in the printed official reports. The official text of the court’s opinion is found in the advance sheets and the bound volumes of the official reports. Also, an electronic version (intended to mirror the language found in the official reports) of the revised opinion can be found, free of charge, at this website: https://www.lexisnexis.com/clients/wareports. For more information about precedential (published) opinions, nonprecedential (unpublished) opinions, slip opinions, and the official reports, see https://www.courts.wa.gov/opinions and the information that is linked there. For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON IN CLERK’S OFFICE SEPTEMBER 8, 2022 SUPREME COURT, STATE OF WASHINGTON SEPTEMBER 8, 2022 ERIN L. LENNON SUPREME COURT CLERK

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

KING COUNTY, ) ) Petitioner, ) No. 100731-1 ) v. ) Filed: September 8, 2022 ) THE HON. PHILIP K. SORENSEN, ) ) Respondent. ) )

OWENS, J.—King County asks this court for a writ of mandamus compelling

Judge Philip K. Sorensen, presiding judge of the Pierce County Superior Court, to turn

over court reporters’ backup audiotapes and to search court employees’ private files

and devices for records responsive to its records request.

We dismiss King County’s petition because it fails to demonstrate why we

should grant the extraordinary remedy of a writ of mandamus. In doing so, we hold

that a superior court presiding judge is not the proper subject of a writ of mandamus to

turn over audiotapes or other records under GR 31 or GR 31.1. Additionally, King For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. King County v. Sorensen, No. 100731-1

County has a plain, speedy, adequate remedy that precludes issuing a writ of

mandamus. Accordingly, we dismiss King County’s petition.

I. FACTS AND PROCEDURAL HISTORY

A. LaRose v. King County 1 Trial

Former King County public defender Sheila LaRose sued King County,

alleging a hostile work environment caused by one of her client’s stalking behavior.

The case proceeded to trial before Judge Stanley J. Rumbaugh in Pierce County

Superior Court. At trial, the jury awarded LaRose $7 million in damages, and later,

an additional $4,927,912.27 was awarded in attorney fees and costs.

King County appealed the judgment. The appeal was stayed pending King

County’s petition for a writ of mandamus before this court. Through its petition,

King County seeks all audio recordings from the trial to evaluate and present issues

related to potential judicial misconduct by Judge Rumbaugh, which brings us back to

the LaRose trial.

During trial, Patty Eakes, of the Calfo Eakes law firm and counsel for King

County, became concerned that Judge Rumbaugh was hostile toward her in front of

the jury and that such hostility gave the jury a negative impression of her, King

County, and their side of the case. Other witnesses similarly viewed Judge

Rumbaugh’s comments as being hostile toward Ms. Eakes.

1 No. 15-2-13418-9 (Pierce County Super. Ct.). 2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. King County v. Sorensen, No. 100731-1

To assess whether King County had a viable claim for judicial misconduct,

Ms. Eakes moved for production of the audio recordings of the trial. Judge

Rumbaugh denied the motion, telling Ms. Eakes that she could file a public records

request, but that the court does not turn over audio tapes. Later that day, Ms. Eakes’

staff e-mailed the court reporters requesting they preserve the audio recordings of

trial. Additionally, Ms. Eakes’ staff formally requested the audio recordings of the

trial from the Pierce County Superior Court under GR 31.1 and Pierce County Local

General Rule (PCLGR) 31.1. The specific request was for “[a]ll audio recordings of

the trial for LaRose v. King County.” Clerk’s Papers (CP) at 87. In response to

Eakes’ request, the Pierce County public records officer, Mary Madden, wrote by

letter that the request was reviewed and that “no records will be provided by Pierce

County Superior Court Administration as we do not have any responsive records.”

CP at 89.

B. Audio Recording Procedures in Pierce County Superior Court

In Pierce County Superior Court, some courtrooms are deemed “electronic”

courtrooms, where an electronic audio recording must be taken and filed with the

court clerk. Other courtrooms are designated as solely “court reporter” courtrooms,

where stenographic notes are the only method of recording proceedings.

The LaRose trial took place in a traditional “court reporter” courtroom. Three

individuals served as court reporters during the LaRose trial. None of these court

3 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. King County v. Sorensen, No. 100731-1

reporters were directed to provide a CR 80 electronic recording of the proceedings in

addition to their stenographic notes.

C. Initial Request for All Documents Related to Audio Recordings

After the trial ended, Calfo Eakes filed another record request, this time under

the Public Records Act (PRA), ch. 42.56 RCW, for all “all audio recordings of the

trial” and “all documents, including written communications (such as emails),

referencing, discussing, or otherwise relating to the recordings of the trial in the

above-referenced case.” CP at 94. Madden responded that while the PRA does not

apply to courts, GR 31 and GR 31.1 cover Calfo Eakes’ request. Madden indicated

that the court would search for responsive records, but that the court did not have any

audio recordings of the trial so there were no responsive audio records. Madden

subsequently informed Calfo Eakes that 252 records were potentially responsive and

that the court needed to finish reviewing those records. Eventually Madden

acknowledged audio recordings of the trial existed, but they were the court reporters’

private work product. Upon reviewing the 252 potentially responsive records,

Madden informed Calfo Eakes that only 7 records were responsive.

King County Senior Deputy Prosecutor David Hackett separately requested the

audio recordings as administrative records under GR 31.1. After further e-mail

exchange, Madden issued a final denial of King County’s request for the audio

recordings, explaining they are not court records under GR 31.

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Bluebook (online)
King County v. Sorensen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-county-v-sorensen-wash-2022.