SEIU Healthcare Northwest Training Partnership, Respondent, v. Evergreen Freedom Foundation, Petitioner., 5 Wn. App. 2d 496

Summary

HOLDINGS: [1]-Replevin under Wash. Rev. Code § 7.64.010 for return of data about the plaintiff's trainees that the defendant obtained in digital form was not preempted by the Uniform Trade Secrets Act, Wash. Rev. Code ch. 19.08, because the replevin statute expressly provides that its remedies are in addition to any other available remedies; [2]-A plaintiff who has alleged (or could allege) misappropriation of a trade secret does not thereby lose the right to seek replevin of property owned by the plaintiff and wrongfully detained by the alleged misappropriator; [3]-Relief under the replevin statute is not based on misappropriation of a trade secret and, therefore, is not displaced by Wash. Rev. Code § 19.108.900(1): the two statutes do not conflict and both can be given effect without distortion of the language used in either.