Washington – Case Law Wire

Bartlett v. Valley Communications Center — 911 Dispatch Agency Faces Negligence Suit Under Special Relationship Exception After Downgrading Murder Scene Call to Priority 2

/ June 9, 2026

The Washington Court of Appeals, Division I, reversed dismissal of a negligence claim against a 911 dispatch agency, holding that the complaint sufficiently alleged the special relationship exception to the public duty doctrine where a dispatcher took a call about an identified murder victim in an identified room, told the caller help was dispatched, and then placed the call on hold—but affirmed dismissal of the negligent supervision claim because the complaint did not allege that any dispatcher acted outside the scope of employment.

Friends of Ravenna-Cowen v. City of Seattle — SEPA Appeals of FEIS Adequacy Not Barred by Housing Reform’s Appeal Prohibition Statutes; One Seattle Plan Environmental Review Must Proceed

The Washington Court of Appeals, Division I, reversed a hearing examiner’s dismissal of SEPA appeals challenging the adequacy of the FEIS for Seattle’s “One Seattle Plan,” holding that state housing reform appeal prohibition statutes (RCW 36.70A.600(3) and RCW 36.70A.680(3)) bar challenges to adopted housing-increasing planning actions but do not bar pre-decisional administrative appeals of FEIS adequacy under SEPA before the City Council votes on the underlying plan.