Division I Decision on the Statute of Limitations for PRA Requests

The Washington Court of Appeals, Division 1, released a published opinion today in Tobin v. Worden. Under RCW 42.56, the statute of limitations to file suit for a Public Records Act request begins when either (1) the agency last claims an exemption; or, (2) last produces a record on an installment basis. The court held that when the King County Department of Development and Environment Services (DDES) produced a single, redacted document and no other documents, the statute of limitations was never triggered and the requesting party’s PRA claim was not time barred.