Wade's Eastside Gun Shop, Inc. v. Dep't of Labor & Indus. (Majority and Dissent)
Annotate this CaseThis appeal arose from an action brought by the Seattle Times against the Department of Labor and Industries (L&I) for withholding nonexempt public records in violation of the Public Records Act (PRA). In October 2012, L&I received a complaint of elevated levels of lead in the blood of two employees working on a remodel of Wade's Eastside Gun Shop. L&I opened investigations into companies that employed workers at Wade's during the remodel. The appeal presented two novel questions about the PRA, and additional fact specific questions: (1) whether a trial court has discretion to calculate penalties for nondisclosure of public records on a per page basis by defining the term "record" to include a single page; (2) whether L&I investigations qualify for the categorical investigative records exemption the Washington Supreme Court has recognized as necessary for "effective law enforcement;" and (3) whether the trial court correctly found that L&I violated the PRA during five separate time periods, and appropriately imposed penalties for each time period. After review of this case, the Washington Supreme Court held that the PRA allowed trial courts to impose penalties calculated on a per page basis, and that L&I could not take advantage of the categorical investigative records exemption in this case. Because L&I did not otherwise demonstrate that any of the public records at issue were exempt from disclosure, and because the trial court acted within its considerable discretion, the Court affirmed the decision.
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