SEIU 775 v. Department of Social & Health Services, 198 Wash. App. 745

SEIU 775 (union for individual providers, “IPs”) sued to block DSHS from releasing times and locations of IP contracting appointments and training after a public records request by the Freedom Foundation.
DSHS located responsive records and planned disclosure; SEIU sought preliminary and permanent injunctions arguing disclosure would violate the Public Employees Collective Bargaining Act (PECBA) and constitute an unfair labor practice.
The trial court denied injunctive relief (with a 14-day stay to permit appeal); this Court temporarily enjoined disclosure pending appeal.
Central legal question: whether PECBA provisions (RCW 41.56.040 and RCW 41.56.140) qualify as an “other statute” exemption to the Public Records Act (PRA) under RCW 42.56.070(1) by expressly prohibiting disclosure of specific records.
The court applied Washington State Patrol’s test: an “other statute” must expressly prohibit or exempt disclosure of specific records or information; courts may not imply such exemptions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether PECBA is an “other statute” exemption to the PRA	PECBA’s prohibitions on interference and unfair labor practices mean releasing IP meeting times/locations would itself be an unfair labor practice, so PECBA implicitly prohibits disclosure	PECBA contains no language addressing records, confidentiality, or disclosure; it does not expressly exempt specific records from PRA production	PECBA is not an “other statute” exemption—it does not expressly prohibit or exempt release of specific records, so PRA disclosure stands

John Doe A v. Washington State Patrol, 185 Wn.2d 363 (2016) (establishes that an “other statute” exemption requires explicit statutory language exempting specific records)
Fisher Broadcasting—Seattle TV LLC v. City of Seattle, 180 Wn.2d 515 (2014) (example where statutory language expressly barred release of dashboard camera recordings)
Ameriquest Mortgage Co. v. Office of the Attorney Gen., 170 Wn.2d 418 (2010) (federal GLBA and FTC rules found to be an "other statute" exemption protecting certain financial information)
Hangartner v. City of Seattle, 151 Wn.2d 439 (2004) (attorney-client privilege statute recognized as an "other statute" exemption due to explicit confidentiality language)
Progressive Animal Welfare Soc’y v. Univ. of Washington (PAWS II), 125 Wn.2d 243 (1994) (anti-harassment and trade-secrets statutes allowed limited nondisclosure; discussed in relation to scope of "other statute")