Stratford v. Umpqua Bank (Majority)
Annotate this CaseAt issue in this case was the “apex doctrine” which shielded certain high-ranking officials from deposition unless the proponent could first show that the witness had personal knowledge of the facts and that a less intrusive means of discovery had been unsuccessful. Respondents Heather Stratford and William Geibel Jr. (collectively Stratford) sued petitioner Umpqua Bank and its loan officer for negligent hiring and fraud, among other claims. After written discovery, Stratford sought to depose three high-level Umpqua executives. Umpqua moved for a protective order, arguing the executives had no personal knowledge and the apex doctrine shielded them from deposition. The trial court denied the motion. The Washington Supreme Court granted Umpqua’s petition for review to decide whether Washington did or should follow the apex doctrine. To this, the Court answered in the negative: the apex doctrine had not been adopted in Washington State, and the Court declined to adopt it because it improperly shifted the burden of proof in violation of Washington discovery rules, and undermined the right of access to courts. The Court affirmed the trial court’s denial of Umpqua’s protective order and remanded for further proceedings.
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