In Caldecott v. Superior Court (Newport-Mesa School Dist.), published December 21, 2015, the Fourth District Court of Appeal, Division 3, issued a writ reversing a trial court's decision denying production of documents under the California Public Records Act. The petitioner was the former executive director of human resources for the real party school district. While he held that position, the petitioner filed a complaint against the district superintendent. The petitioner alleged that the complaint alleged that the superintendent created a hostile work environment, and also alleged improprieties with money. The district alleged that the complaint discussed only personnel matters. The school board responded in writing that it would take no action on the complaint. Shortly afterward, the superintendent terminated the petitioner's employment, and the school board approved the action. The petitioner sought production of the documents under the CPRA. The trial court denied the petitioner's writ petition, on the ground that the petitioner already had the documents.
The appellate court held that the fact the petitioner already had the documents was not a ground for denying the request. The motive of a person requesting documents under the CPRA is irrelevant. Further, the petitioner sought the documents so that he could disseminate them without concern that the district would object. The appellate court ruled that the documents were personnel documents, requiring the court to balance the privacy interest in the documents against the public interest in their disclosure. Since the documents concerned allegations of conduct by a high-ranking official, the appellate court (after an in camera review) determined that the public interest in them outweighed privacy. The court overruled the official information privilege objection to their production, ruling that production would not affect internal deliberation. It directed the trial court, on remand, to review the documents for attorney-client privileged matters, which would not be subject to production. It awarded the petitioner his attorney fees.
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