Officer Doe & Seattle Police Officers Guild V. Seattle Police Department, Et Ano.

Court of Appeals of Washington·Decided August 3, 2026·No. 87857-3·Unpublished

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

OFFICER DOE; and SEATTLE POLICE OFFICERS GUILD, No. 87857-3-I

Appellants, DIVISION ONE

v. UNPUBLISHED OPINION

SEATTLE POLICE DEPARTMENT; and THE CITY OF SEATTLE,

Respondents,

and,

REQUESTOR # 1; and REQUESTOR # 2,

Defendants.

HAZELRIGG, C.J. — In this third-party litigation under the Public Records

Act, 1 Officer Doe, a Seattle Police Department employee appearing under

pseudonym, and the Seattle Police Officers Guild appeal from the order entered

following a trial by affidavit. On appeal, Doe and the Guild do not challenge the

portion of the trial court’s ruling that granted their request to redact Doe’s

identifying information from certain records responsive to two public records

requests. Rather, they assign error to the court’s rejection of their separate request

for further declaratory relief that sought such redactions on behalf of all existing

and future Guild members for all similar future public records requests on the basis

1 Chapter 42.56 RCW. No. 87857-3-I/2

that it was nonjusticiable. The court did not err when it denied such relief, and we

affirm.

FACTS

The following circumstances prompted both the creation of the records

responsive to two public disclosure requests submitted to the City of Seattle and

the complaint later filed by Officer Doe and the Seattle Police Officers Guild

seeking redaction of those records.

In November 2021, Doe, a detective with the Seattle Police Department

(SPD), investigated Abdullahi Ali on suspicion of having committed robbery. Doe

recommended that Ali be charged with multiple counts of robbery in the first

degree. Thereafter, and continuing on through August 2022, Ali and his associates

filed more than 30 complaints against Doe with the City of Seattle’s Office of Police

Accountability (OPA). Their complaints alleged, among other things, that Doe was

racist, trafficked in controlled substances as part of a gang, had “rubbed” a

handcuffed suspect in a sexual manner, and after several such OPA complaints

had been filed against Doe, that Doe had offered to lessen Ali’s criminal charges

if Ali withdrew his complaints against Doe.

From these 30 complaints, OPA opened seven investigations into Doe, and

the City’s Office of Inspector General (OIG) also opened a separate investigation.

Each investigation determined that the complaints to the OPA against Doe were

“not sustained.”2 OPA concluded that the complaints relied on fictitious witnesses

2 Ali was later arrested by the Seattle Police Department on suspicion of felony stalking of

Officer Doe under RCW 9A.46.110(5). The certification for determination of probable cause filed against Ali regarding that arrest was based, at least in part, on the conduct described herein.

-2- No. 87857-3-I/3

and none had merit. 3 The final determination of the OIG stated, “Based on this

preliminary investigation and analysis of its aggregated information, OIG finds that

the complaints lodged against [Doe], discussed within this report appear to be

without merit.”4

During this time, two public disclosure requests were submitted for the

records related to OPA’s investigation into Doe. The City notified Doe, as well as

the Seattle Police Officers Guild, that records responsive to those requests

contained certain identifying information regarding Doe and, pursuant to City

policy, it intended to disclose those records without redacting that information. 5

Doe and the Guild subsequently filed a complaint against the City and

individuals identified as Requestor #1 and Requestor #2. Their complaint alleged

the conduct by Ali and his associates, described supra, relied on several privacy-

related statutory exemptions under the PRA to argue that Doe’s right to privacy

under that act would be violated unless the City appropriately redacted Doe’s

identity, and requested that the court issue a permanent injunction that ordered the

City to redact Doe’s identity from those responsive records pursuant to the PRA. 6

The parties later agreed to a trial by affidavit. Significantly, in Doe’s and the

Guild’s trial brief they presented, for the first time, an additional request to the court:

3 During this time, Ali, through his counsel, also attempted to withdraw all of his OPA

complaints against Doe. 4 The trial court found, regarding the specific “investigations of allegations of misconduct

against Officer Doe” set out supra, that Doe “has been cleared of any wrongdoing. OPA and OIG determined all the allegations of misconduct to be unfounded.” 5 SPD notified the Guild of the public records requests pursuant to its collective bargaining

agreement (CBA) with the Guild. 6 Doe’s and the Guild’s complaint also requested declaratory relief that disclosure of the

records in question without the requested redactions would violate the PRA. This relief inhered in their request for a permanent injunction from the court under the PRA.

-3- No. 87857-3-I/4

Beyond Officer Doe’s rightful claim that her identifying information be exempt from disclosure, the Guild also requests this [c]ourt enter [d]eclaratory [j]udgment holding that all Guild members who will, in the future, be the subjects of unsubstantiated allegations of racism, official dishonesty, corruption, and targeted/retaliatory policing have their identities exempt from disclosure under the PRA’s privacy exemption and, if applicable, per RCW 42.56.240(2). 7

(First emphasis added) (footnote omitted).

The trial by affidavit commenced in October 2024, and the court later

entered a detailed written order setting forth its findings of fact and conclusions of

law. 8 Based on the facts before it, the court concluded that the PRA granted Doe

a right to protect their identity as contained in the records responsive to the public

disclosure requests in question and ordered the City to redact Doe’s identifying

information from those records. 9 The court then rejected as nonjusticiable Doe’s

and the Guild’s request for additional declaratory relief.

Doe and the Guild timely appealed.

ANALYSIS

7 RCW 42.56.240(2) governs the PRA’s exemption applicable to “[i]nformation revealing

the identity of persons who are witnesses to or victims of crime or who file complaints with investigative, law enforcement, or penology agencies, other than the commission, if disclosure would endanger any person’s life, physical safety, or property.” 8 In its order, the court found that the requestors “never appeared or participated in this

action, and failed to appear at trial” and, accordingly, ruled that they defaulted at trial. 9 Additionally, as part of the court’s order, it ruled, pursuant to the CBA provision, that

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