Terry Cousins v. Dep't of Corrections

Court of Appeals of Washington·Decided August 25, 2026·No. 41279-2·Published

Opinion

FILED

AUGUST 25, 2026

In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

TERRY COUSINS, ) No. 41279-2-III )

Respondent, )

)

v. ) PUBLISHED OPINION )

STATE OF WASHINGTON and ) DEPARTMENT OF CORRECTIONS, )

)

Appellants. )

LAWRENCE-BERREY, J. — The Department of Corrections (DOC) appeals after the trial court awarded Terry Cousins over $1,000,000 in Public Records Act (PRA), chapter 42.56 RCW, penalties and over $200,000 in attorney fees and costs.

We conclude that the trial court erred when it included duplicated records earlier produced timely and nonresponsive records in its finding that DOC unreasonably delayed producing 434 records. The evidence supports a finding that DOC unreasonably delayed producing only 69 records.

We affirm the trial court’s determination that DOC violated the PRA and its finding of the number of days DOC unreasonably delayed producing records. We reverse its penalty award and its attorney fee/cost award and remand for a new determination of those awards.

Cousins v. DOC

FACTS

On April 11, 2016, Terry Cousins, through counsel, sent a preservation letter to DOC for all documents surrounding the confinement and death of her sister, Renee Field, who had been in DOC’s custody. On July 21, 2016, Cousins made a public records request to DOC for “‘any and all records regarding Renee A. Field . . . from January 1, 2014, to present.’” Clerk’s Papers (CP) at 1978. Due to the breadth of the request and the number of places within DOC where responsive records might be located, DOC realized early on that the record request would be complex and numerous people would be involved in responding to the request.

DOC promptly acknowledged Cousins’ request for records, and, on October 28, 2016, it notified her that the first installment of records was available. Between November 22, 2016 (after Cousins paid for the first installment) and January 17, 2019 (when DOC notified Cousins that all responsive records had been provided), DOC sent Cousins seven records installments.

Cousins reviewed the seventh installment, and, in late January 2019, e-mailed her contact at DOC, Sheri Izatt, of her belief that several records were missing, and described with some particularity what those records were. Izatt provided less than clear assurances

Cousins v. DOC

to Cousins that she would search for those records. Over the next several months Cousins left voicemails for Izatt, but Izatt had left DOC without informing Cousins.

In late October 2019, Izatt’s replacement, Paula Terrell, received one of Cousins’

voicemails and responded. Terrell mistakenly believed that Cousins’ attorney was the proper requestor of the records and told Cousins she would not respond to her. Later, Terrell mistakenly told Cousins that her records request “‘is and remains closed’” and attached the cover letter from the seventh record’s installment. CP at 1982.

In her deposition, Terrell admitted that she should have reopened Cousin’s request in November 2019. Because of Terrell’s mistakes, DOC did not produce the eighth installment of records until October 1, 2020. DOC did not charge Cousins for the eighth and subsequent installment of records.

On January 12, 2021, Cousins filed suit against DOC for violating the PRA, seeking penalties and attorney fees. In her February 24, 2021, amended complaint, Cousins acknowledged that all of the records DOC produced in the eighth, ninth, and tenth installments were duplicates of earlier produced records. In August 2021, DOC produced its seventeenth and final installment of records to Cousins.

DOC filed a motion to dismiss based on its contention that the one-year period to file a PRA action had expired. It argued the date the one-year period commenced was

Cousins v. DOC

January 17, 2019, when it informed Cousins that all records responsive to her request had been produced. The trial court agreed and dismissed Cousins’ action. Our Supreme Court reversed and remanded. Cousins v. State, 3 Wn.3d 19, 546 P.3d 415 (2024).

On remand, the trial court conducted a show cause hearing based on documents only. DOC maintained that it did not violate the PRA and argued that its responses through the seventh installment were timely. The parties and the trial court focused on the lengthy delay between the seventh and eighth installments. Cousins counted the number of records produced from the eighth to the seventeenth installments and argued that the number of records unreasonably delayed totaled 434, but she admitted she had not deducted the duplicated records.

DOC then went through each installment, one at a time, and identified which of the 434 records were nonduplicative documents responsive to Cousins’ public records request. Based on its review, DOC concluded that only 69 of the 434 records were nonduplicative responsive records.

Cousins did not identify any error in DOC’s review. Instead of disputing DOC’s conclusion, Cousins argued that duplicated records could be counted in a PRA penalty and stated (without specifying any specific record) that some duplicates might have been less redacted.

Cousins v. DOC

The trial court found that DOC produced 434 records to Cousins after the seventh installment and the appropriate penalty period was 623 days, which spanned from January 17, 2019 (the date of the seventh installment) until October 1, 2020 (the date of the eighth installment). The trial court concluded that a per diem penalty was appropriate once a violation of the PRA had been found for an unreasonable delay in producing records.

With respect to the per diem amount, the court found “more [Yousoufian1]

mitigating factors than aggravating factors” because DOC “did not act dishonestly, intentionally, or in bad faith.” CP at 1985. It described DOC’s actions “in line with the ‘big-whiff’ type of case.” CP at 1985. The court used a $4 per diem penalty and, based on the number of records (434) and the number of days of unreasonable delay (623), it calculated a total penalty of $1,081,528. It later awarded Cousins reasonable attorney fees and litigation costs in the amounts of $199,482.50 and $8,165.79, respectively.

DOC appeals to this court.

1 Yousoufian v. Office of Ron Sims, 168 Wn.2d 444, 229 P.3d 735 (2010).

Cousins v. DOC

ANALYSIS

STANDARD OF REVIEW “We review de novo an order on a motion to show cause when, as here, the record ‘consists entirely of written materials and the trial court has not seen or heard testimony requiring it to assess the credibility or competency of a witness, weigh evidence, or reconcile conflicting evidence.’” 2 C.S.A. v. Bellevue Sch. Dist. No. 405, 32 Wn. App. 2d 544, 556, 557 P.3d 268 (2024) (quoting Gronquist v. Dep’t of Corr., 159 Wn. App. 576, 590, 247 P.3d 436 (2011)), review denied, 4 Wn.3d 1019, 566 P.3d 92 (2025). “We also review de novo a trial court’s PRA determination ‘where the record consists only of affidavits, memoranda of law, and other documentary evidence’ because we ‘stand[ ] in the same position as the trial court.’” Id. (alteration in original) (quoting Progressive Animal Welfare Soc’y v. Univ. of Wash., 125 Wn.2d 243, 252, 884 P.2d 592 (1994) (plurality opinion)).

2 Cousins’ argument that some of the duplicated records might have been less redacted is speculative, and does not require us to reconcile conflicting evidence. Gardner v. Seymour, 27 Wn.2d 802, 808, 180 P.2d 564 (1947) (the existence of a disputed fact cannot rest on guess, speculation, or conjecture).

Cousins v. DOC

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