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Keywords

litigationdiscoverytrialharassmentleaserespondent
litigationdiscoverytrialharassmentleaserespondent

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Seattle Times Co. v. Rhinehart, 467 U.S. 20, 104 S.Ct. 2199, 81 L.Ed.2d 17, 38 Fed.R.Serv.2d 1606, 10 Media L. Rep. 1705

Facts

Respondent Rhinehart, the spiritual leader of the Aquarian Foundation, and other members brought a defamation action against the Seattle Times and the Walla Walla Union–Bulletin after the newspapers published several articles about them. During discovery, the respondents refused to disclose the identities of the Foundation's donors and members, leading the trial court to compel their disclosure while also issuing a protective order to prevent the newspapers from disseminating this information. The protective order was based on concerns that public release would adversely affect the Foundation's membership and income, as well as expose its members to harassment.

Respondent Rhinehart, the spiritual leader of the Aquarian Foundation, and other members brought a defamation action against the Seattle Times and the Walla Walla Union–Bulletin after the newspapers published several articles about them. During discovery, the respondents refused to disclose the identities of the Foundation's donors and members, leading the trial court to compel their disclosure while also issuing a protective order to prevent the newspapers from disseminating this information. The protective order was based on concerns that public release would adversely affect the Foundation's membership and income, as well as expose its members to harassment.

Issue

Whether parties to civil litigation have a First Amendment right to disseminate, in advance of trial, information gained through the pretrial discovery process.

Whether parties to civil litigation have a First Amendment right to disseminate, in advance of trial, information gained through the pretrial discovery process.

Rule

A protective order may be issued under Rule 26(c) of the Washington Civil Rules to protect a party from annoyance, embarrassment, oppression, or undue burden, provided there is good cause shown.

A protective order may be issued under Rule 26(c) of the Washington Civil Rules to protect a party from annoyance, embarrassment, oppression, or undue burden, provided there is good cause shown.

Analysis

The court applied the rule by determining that the protective order was justified to protect the privacy interests of the Foundation and its members. It noted that the information sought was sensitive and that public disclosure could lead to harassment and reprisals. The court emphasized that the protective order did not prevent the dissemination of information obtained from other sources, thus balancing the need for confidentiality with First Amendment rights.

The court applied the rule by determining that the protective order was justified to protect the privacy interests of the Foundation and its members. It noted that the information sought was sensitive and that public disclosure could lead to harassment and reprisals. The court emphasized that the protective order did not prevent the dissemination of information obtained from other sources, thus balancing the need for confidentiality with First Amendment rights.

Conclusion

The Supreme Court of Washington affirmed the trial court's protective order, concluding that it did not offend the First Amendment as it was limited to the context of pretrial civil discovery and did not restrict dissemination of information obtained from other sources.

The Supreme Court of Washington affirmed the trial court's protective order, concluding that it did not offend the First Amendment as it was limited to the context of pretrial civil discovery and did not restrict dissemination of information obtained from other sources.

Who won?

Respondents (Rhinehart and the Aquarian Foundation) prevailed because the court upheld the protective order, recognizing their privacy interests and the potential harm from public disclosure.

Respondents (Rhinehart and the Aquarian Foundation) prevailed because the court upheld the protective order, recognizing their privacy interests and the potential harm from public disclosure.

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