Tiberino v. Spokane County
In Tiberino v. Spokane County, 103 Wn. App. 680, 13 P.3d 1104 (Wash. 2000), a former government employee sought an injunction to block the public release of emails that were written by her, but printed by her employer, in preparation for litigation over the employee's alleged wrongful termination.
The employee had been terminated, in part, for excessive use of office email for personal reasons.
The media became interested in the contents of the emails, and asked the agency to release them. Not wanting the emails to become public, the former employee attempted to stop their release pursuant to the "personal privacy" exemption in Washington's Public Records Act.
The Washington Supreme Court ruled that the emails were not exempt from disclosure under that specific exemption, but rather exempt under section 42.17.255, a provision that exempts documents which contain highly offensive intimate details, and which also lack legitimate public concern. Wash. Rev. Code 42.17.255 (1972).