Pasadena Police Officers Ass'n. v. Super. Ct.Annotate this Case
This case concerns requests under the California Public Records Act (PRA), Gov. Code, 6250 et seq.; Cal. Const., art. I, 3, subd. (b), seeking disclosure of the OIR’s August 2014 “Report to the City of Pasadena Concerning the Officer-Involved Shooting of . . . McDade[.]” Petitioners initiated this reverse PRA action, seeking to enjoin disclosure of the Report. The court denied the petition by which petitioners seek to preclude disclosure of the entire Report or, in the alternative, the production of a more heavily redacted Report; the court concluded that the trial court correctly concluded that the Report itself is a public document; the trial court also correctly determined that portions of the Report contain confidential personnel information exempt from disclosure under the PRA; the court's review of the sealed materials in the record reveals that some of the material the trial court ordered redacted from the Report is unrelated to personnel files of individual officers; and the inappropriately redacted material includes analyses of the PPD’s administrative investigation and departmental policies, descriptions of the PPD’s responsiveness (or the absence thereof), and recommendations by the OIR, none of which is privileged under the PRA. Accordingly, the court denied the petition and remanded the matter to the superior court with directions to conduct new proceedings, and issue a new or modified judgment.