City of San Jose v. Superior CourtAnnotate this Case
Petitioner requested disclosure of thirty-two categories of public records from the City of San Jose, its redevelopment agency and executive director, and other elected officials and their staffs, seeking documents concerning redevelopment efforts in downtown San Jose. Included in the request was emails and text messages sent or received on private electronic devices used by the mayor, two city council members, and their staffs. The City disclosed certain communications but did not disclose communications made suing the individuals’ personal accounts. Petitioner sued for declaratory relief under the California Public Records Act (CPRA), arguing that messages communicated through personal accounts are public records. The trial court granted summary judgment for Petitioner and ordered disclosure. The Court of Appeal, however, issued a writ of mandate. The Supreme Court reversed, holding that a city employee’s writings about public business are not excluded from CPRA simply because they have been sent, received, or stored in a personal account. Remanded.