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Washington Prison File Inspection Request is PRA Request

The Washington Court of Appeals held that a prisoner's request to review his central file was a Public Records Act (PRA) request.

On May 3, 2010, an attorney for Washington prisoner Marvin Hunter requested the opportunity to review Hunter's Department of Corrections (DOC) central file. DOC denied the request.

On January 4, 2012, the trial court denied Hunter's request for an in camera review of the withheld documents, concluding that Hunter's request was not a PRA records request. On January 24, 2013, the court denied Hunter's motion for reconsideration and on March 21, 2013, the court denied his motion for attorney fees and penalties.

The Washington Court of Appeals accepted DOC's concession that the trial court incorrectly concluded that Hunter's request was not a PRA request and remanded to the trial court.

Citing Seattle Times Co v. Serko, 170 Wn2d 581, 593-94, 243 P2d 919 (2010), Hunter argued that the trial court had no discretion to refuse to conduct an in camera review. Nevertheless, the court refused to order an in camera inspection on remand, leaving it to the trial court to determine whether such inspection is required.

The court also vacated the trial court's order denying Hunter attorney fees and penalties. Hunter's request for attorney fees on appeal was referred to the trial court pursuant to RCW 42.56.550(4), but the court awarded Hunter his statutory costs on appeal. See: Hunter v. Washington State Department of Corrections, Wn2d P.3d (Wa App Ct. 2014).

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Related legal case

Hunter v. Washington State Department of Corrections