Gendler v. Batiste
Annotate this CaseRespondent Michael Gendler made a public records request for location-specific accident reports from the Washington State Patrol (WSP). The WSP refused to provide the records unless Gendler certified that he would not use the records in any litigation against the State, claiming a federal statute (23 U.S.C. sec. 409) protected the records sought. WSP claimed the records were shielded because they were located in an electronic database that the Department of Transportation (DOT) utilized for purposes related to the federal hazard elimination program. Respondent then brought a suit under the PRA and argued section 409 did not apply to the WSP because it did not compile or collect the information for the hazard elimination program's purposes. Rather, the information was collected pursuant to WSP’s statutory duty under RCW 46.52.060. The trial court agreed and on summary judgment ordered WSP to produce the requested accident reports. The Court of Appeals affirmed. The Supreme Court also affirmed because section 409 does not extend to police accident reports generated and received by WSP pursuant to its own statutory duty.
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