Progressive Animal Welfare Society v. the University of Washington

Summary

The court held that an unfunded university grant proposal was not categorically exempt from disclosure under the Public Records Act, although specific research data, hypotheses, trade-secret material, and other protected information could be redacted. It also held that confidential peer-review materials remained exempt while the proposal was unfunded, rejected constitutional academic-freedom and federal-preemption defenses, and required the University to identify and disclose all responsive records subject to applicable exemptions. The judgment was affirmed in part and reversed in part because factual questions remained regarding silent withholding and the completeness of the records produced. Andersen, C.J., concurring, accepted the majority's legal analysis while urging legislative protection for medical research; Brachtenbach, J., dissenting, would have upheld nondisclosure under the injunction provision.