[co-author: Sara Alstrom - summer associate]
In Lyft, Inc. v. City of Seattle, the Washington Supreme Court found that the proper standard for injunctive relief under the Public Records Act (PRA) is the standard outlined in RCW 42.56.540, which is stricter than the standard for injunctive relief under Civil Rule 65.
Under the PRA, public records may be withheld when an exemption applies. In Lyft, quarterly zip code reports were submitted by ride-sharing companies Lyft and Rasier (subsidiary of Uber) to the City of Seattle for regulatory enforcement, service disparity analysis, and resource allocation. The companies designated the reports “confidential.” When a request was made under the PRA, the companies argued that the reports should be withheld from disclosure as trade secrets.
The Washington Supreme Court ruled that although the reports may qualify as trade secrets under the Uniform Trade Secrets Act, the trial court applied the wrong standard for enjoining disclosure. The Court explained that the PRA’s more stringent standard for injunctive relief applies. Under that standard, to issue an injunction against the release of a public record a court must engage in a two-step analysis: (1) whether the public record is subject to an exemption under any PRA provision or an applicable “other statute,” and (2) whether the party seeking to enjoin disclosure has shown that disclosure is clearly not in the public interest, and would result in substantial and irreparable harm to any person or vital government interest. The Court reasoned that “[g]iven the broad range of ‘other statutes’ the courts consider in connection with the PRA, consistent application of the PRA requires the consistent procedural operation of the PRA injunction standard regardless of the exemption or ‘other statute’ asserted.”
Practically speaking, this case confirms the risks inherent in submitting confidential business information to government entities for regulatory purposes and clarifies the applicable standard in seeking to enjoin release of confidential documents.
