Los Angeles Bd. Of Supervisors v. Super. Ct.
Annotate this CaseThe ACLU submitted a California Public Records Act (CPRA) request to Los Angeles County for invoices from any law firm in connection with nine lawsuits “brought by inmates involving alleged jail violence.” It also sought disclosure of service agreements between the County and two consultants and an “implementation monitor.” The County agreed to produce copies of the requested documents related to three lawsuits, which were no longer pending, with attorney-client privileged and work product information redacted. It declined to provide statements for the remaining lawsuits, which were still pending. It averred that the “detailed description, timing, and amount of attorney work performed, which communicates to the client and discloses attorney strategy, tactics, thought processes and analysis” were privileged and exempt from disclosure under Government Code 6254 (k), and 6255(a), and by Business and Professions Code 6149 and 6148. The superior court granted a writ of mandate insofar with respect to billing records, but denied the petition with respect to the agreement between the County and the implementation monitor. The court of appeal vacated, holding that because the CPRA expressly exempts attorney-client privileged communications, the tension must here be resolved in favor of the privilege. Because the invoices are confidential communications under Evidence Code 952, they are exempt from disclosure under Government Code 6254(k).
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