O'Neill v. City of Shoreline
Oct 07, 2010OUTCOME: Affirmed in part, reversed in part. Remanded.
Facts: Woman present at a public meeting of the city council makes Public Records Act request for an email referenced at the same meeting--the deputy mayor referred to the woman as the author of the em ... ail, which she was not. City provided only paper copies of the email, with alterations, instead of the email in its native electronic format (with metadata intact); woman made subsequent PRA requests to get the metadata for the email so she could see how, and to whom, it was sent, received, etc. The email was later inadvertently destroyed, very near the time of a specific request for the metadata of the email itself. Woman brings suit, and files a motion to set a show cause hearing. Trial court dismissed the case sua sponte without holding a show cause hearing, and after considering evidence presented by both sides. Woman appealed. Court of Appeals ruled that at least some portion of the requested metadata is a public record and that remand was necessary to determine whether the original email (still not provided) could be located or recovered. The Court did not rule on the dismissal issue. The Supreme Court accepted review in April of 2008. Oral argument was held in March of 2010. The State Supreme Court concluded that metadata is a public record, but refrained from concluding that the City violated the PRA. Instead, the Court remanded and gave the City the chance to forensically locate and produce the requested public record. The trial eventually granted summary judgment in favor of the requestor. Outcome: Affirmed in part, reversed in part. Remanded.
