Disclosure of Juvenile Law Enforcement Records

Overview

Agency disclosures of juvenile case records are governed exclusively by chapter 13.50 RCW, which courts recognize as an “other statute” under the Public Records Act (PRA), chapter 42.56 RCW.  See Wright v. State (2013) and Doe v. Thurston County (2025). But agencies can nonetheless still use PRA policies and procedures to track and/or process requests for these records.

RCW 13.50.010(1)(f) defines juvenile “records” as official juvenile court files and other juvenile case records held by “juvenile justice or care agencies” including police, prosecutors or defense attorneys, detention centers, or diversion units. See RCW 13.50.010(1)(c). 

As explored below, chapter 13.50 RCW imposes different disclosure requirements depending on whether involved records relate to juvenile criminal or non-criminal cases. 

Juvenile Criminal Records

RCW 13.50.050(3) generally prohibits agencies from disclosing records relating to the commission of juvenile offenses, even those pertaining to juveniles that have since reached adulthood. Agencies can only disclose these records in limited circumstances, such as:

• Under RCW 13.50.050(4) agencies can disclose these records to other juvenile justice care system “participants” (such as police, prosecutors, or social service agencies like DCYF), but only if the other participant is pursuing an investigation or case involving the subject juvenile or is responsible for supervising the juvenile.
• Unless RCW 4.24.550 (pertaining to sex offenders and kidnappers) applies, agencies can only publicly disclose juvenile criminal records located outside official juvenile court files if the disclosed information cannot reasonably be expected to identify the juvenile or their family. See RCW 13.50.050(5). For comparison, records located within official juvenile court files are open to public inspection unless sealed by the court. See RCW 13.50.050(2). 

• The discovery authorities applicable to adult investigations and prosecutions (such as CrR 4.7) regulate the release of juvenile criminal law enforcement and prosecutor records to the juvenile themselves or to their attorney. Accordingly, a juvenile’s parents or attorney are generally not entitled to receive these records through public records requests. See RCW 13.50.050(6). 
• Under RCW 13.50.050(9), agencies must disclose an alleged or proven juvenile offender’s identity and the circumstances of their alleged or proven crime to the crime victim or the victim’s immediate family upon request.
• RCW 13.50.050(7) provides that law enforcement and prosecutors can release juvenile criminal case information to the juvenile’s school once law enforcement has decided to arrest (or has arrested) the juvenile. However, agencies can withhold these records from the school if disclosure would “jeopardize the investigation or prosecution or endanger witnesses.”

What about criminal case records that pertain to both juvenile and adult offenders?

Agencies often struggle to apply the chapter 13.50 RCW disclosure restrictions when criminal investigative records involve both adult and juvenile suspects or offenders. Little legal authority directly addresses this subject, but the case of Does 1-4 v. King County (2021) is instructive. The court in that case upheld the agency’s decision to apply chapter 13.50 RCW in a public records request by redacting the juvenile offender’s information from a combined adult-juvenile criminal report (rather by withholding the report entirely as a juvenile record).

Juvenile Records Sealed by Court Order

Note also that juvenile courts can order juvenile case records sealed pursuant to RCW 13.50.260, so consulting the prosecutor to determine whether records are subject to a sealing order is a good agency practice before disclosure. If a court order seals the records, RCW 13.50.260(6)(a) requires agencies to “reply to any inquiry concerning confidential or sealed records that records are confidential” and prohibits disclosing information “about the existence or nonexistence of records concerning an individual.”  

Despite this restriction, Washington state criminal justice agencies can access sealed juvenile records. Non-Washington criminal justice agencies can also access them but only for purposes related to processing and purchasing firearms or CPLs or releasing firearms from evidence. See RCW 13.50.260(8)(d) and (e).

Non-Criminal Juvenile Records

RCW 13.50.100 generally prohibits agencies from disclosing juvenile records that do not relate to the commission of a crime. Potential examples include Department of Social and Health Services records of services provided to a juvenile domestic violence victim, police runaway reports, or juvenile school records related to services or truancy.

But the statute provides notable exceptions. For example:

• RCW 13.50.100(7) allows agencies to release these records to the juvenile or their attorney, parents, and/or parents’ attorney upon request. But the agency must withhold the information if it determines that releasing it is likely to cause severe psychological or physical harm to the juvenile or the parents, or the records relate to certain counseling, psychological, psychiatric, or medical services provided to the juvenile.
• RCW 13.50.100(3) also allows agencies to release these records to Child Protective Services or other juvenile justice or care system participants that are pursuing an investigation or case involving the juvenile or are responsible for supervising the juvenile.
• RCW 13.50.100(10) allows parties in proceedings seeking dependency declarations or parent-child relationship termination to recover attorney fees, costs, and penalties of $5 to $100 per day against agencies that wrongfully deny their discovery request for juvenile justice and care records.