Pierce County v. Guillen
Headline: Federal highway‑safety evidence rule is upheld, protecting reports compiled or collected for safety programs and making it harder for accident victims to obtain some local records in court.
Holding: The Court held that the federal law known as 23 U.S.C. §409 is constitutional under the Commerce Clause and protects materials compiled or collected for §152 highway‑safety work, but does not shield unrelated state records.
- Limits plaintiffs’ access to highway‑safety documents compiled or collected for federal §152 projects.
- Encourages states to collect candid safety data without fear of litigation exposure.
- Leaves records created for other state purposes generally available from original agencies.
Summary
Background
This case arose after a fatal car crash at the 168/B intersection in Pierce County, Washington. The county applied for federal Hazard Elimination Program (§152) funds and gathered accident reports, collision diagrams, and other documents. Family members of the deceased sought those records in both a public‑disclosure suit and a negligence suit. Congress had passed 23 U.S.C. §409 to bar discovery and admission of materials "compiled or collected" for certain federal highway‑safety programs.
Reasoning
The Court first decided how to read §409. It held the statute protects only materials actually compiled or collected for §152 purposes, not records originally created for unrelated state uses and kept by the original agency. The Court explained the 1995 change adding "or collected" was meant to cover materials gathered for §152 work. On the constitutional question, the Court found Congress acted within its Commerce Clause power because protecting candid information collection could improve safety in interstate commerce. It reversed the Washington Supreme Court’s contrary ruling.
Real world impact
After this decision, state and local agencies may withhold from discovery and trial materials they themselves compiled or collected for §152 highway‑safety projects. Records created for other state purposes and retained by the original agency generally remain obtainable. The Supreme Court reviewed only the public‑disclosure case and dismissed review of the ongoing negligence suit for want of jurisdiction.
Dissents or concurrances
Three Justices agreed with the outcome but wrote separately, preferring a narrower reading of the statute’s scope.
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