Laborers International Union of North America v. City of Aberdeen

Is a labor union entitled, because of the Washington public disclosure act, to inspect unexpurgated copies of a private contractors payroll records filed with a city pursuant to a public contract, in order to verify the contractors compliance with federal public project wage laws? The union brought this action in superior court claiming it is. The City of Aberdeen, conceding that such payroll records are public records, contended that only copies edited to delete information that would identify specific employees should be furnished. The contractor, Felton Construction, intervened contending no part of the record should be available. The trial court agreed with the City and entered an order accordingly. We reverse, holding that the payroll records are public records, that no exemption applies and therefore the union is entitled to access to the unexpurgated version.