In Progressive Animal Welfare Society v. University of Washington, the Washington State Supreme Court held that Washington\u27s Public Disclosure Act mandated public access to unfunded medical research grant proposals submitted by researchers to public institutions within the state. This holding conflicts with federal policy and the current national standard of maintaining full confidentiality of research grant proposals until after research actually is funded. This Note examines the harmful impact that this decision will have on medical research conducted in Washington and the implications for Washington\u27s biotechnology industry. It recommends that both the Washington legislature and Congress act to ensure that unfunded medical research proposals are exempt in their entirety from state and federal public disclosure laws
