Tiberino v. Spokane County

13 P.3d 1104 (2000)

From our private database of 46,100+ case briefs, written and edited by humans—never with AI.

Tiberino v. Spokane County

Washington Court of Appeals
13 P.3d 1104 (2000)

LJ

Facts

Gina Tiberino (defendant) was an employee of Spokane County (the county) in Washington. Specifically, Tiberino served as a secretary in the prosecuting attorney’s special assaults unit. As part of her employment with the county, Tiberino was provided with a work computer. During training, Tiberino was instructed by her supervisor that the computer was not for personal use and that because the county was subject to an open-records law, she should not send or receive information that she would not be comfortable seeing on the front page of a newspaper. In October 1998, the county received complaints from Tiberino’s coworkers regarding her work habits, and specifically, that she used her work computer for personal matters. The county’s office administrator investigated the coworkers’ complaints and inspected Tiberino’s computer. The office administrator determined that of 214 total emails sent, 200 related to personal matters and only 14 appeared to be work related. In November, Tiberino was terminated from the county because of her unsatisfactory job performance. The reason for her termination was her preoccupation with personal issues during work time. On December 1, Tiberino’s attorney threatened litigation against the county and demanded Tiberino’s reinstatement. On December 16, a news reporter (plaintiff) filed an open-records request for correspondence to and from Tiberino during her employment. Pursuant to Tiberino’s request, the trial court issued a temporary restraining order in order to prevent the county from releasing the documents. Additional media outlets (plaintiffs) intervened in the action seeking the release of the emails. The superior court conducted an in-camera review and held that Tiberino’s email communications were public records within the meaning of the open-records act. Tiberino filed an appeal, asserting that her personal emails were not public records because they did not contain information regarding the government’s conduct or function.

Rule of Law

Issue

Holding and Reasoning (Kurtz, C.J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 748,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 748,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,100 briefs, keyed to 987 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 748,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,100 briefs - keyed to 987 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership