When considering whether three high-level Umpqua Bank executives could be shielded from having to appear at deposition in a negligent hiring lawsuit, the Washington Supreme Court unanimously rejected the financial institution's arguments and encouragement to adopt the so-called "apex doctrine."

The apex doctrine shields certain high-ranking officials from deposition unless the proponent can show that the witness has "personal knowledge of the facts and that less intrusive means of discovery have been unsuccessful." But in the case before the state high court, it was an issue for the court to decide whether Washington does or should follow the apex doctrine.