Fredericks v. Super. Ct.
Annotate this CasePetitioner Farhad Fredericks made a California Public Records Act (CPRA) request to defendant and real party in interest, the City of San Diego and the San Diego Police Department (the Department), for all "complaints and/or requests for assistance" made to the Department during a six-month period (180 days), pertaining to burglary and identity theft. In response to the request, the Department notified Fredericks that its investigation reports were exempt from disclosure under the CPRA, but it would provide him with redacted, summarized information in its relevant "Calls for Service" reports (e.g., deletion of names of victims), but only about incidents that had occurred during the 60 days before the date of the request. If he continued to seek the Incident History Reports for the same period, they would be provided in redacted form, conditioned on payment of costs for staff preparation costs, plus charged per page disclosed. In response, Fredericks filed a petition for writ of mandate with the trial court to challenge the Department's incomplete compliance with his request. The trial court denied the petition, reasoning that the CPRA only requires the Department to provide information relating to current or "contemporaneous" police activity. In this original proceeding, the Court of Appeal addressed the interpretation of CPRA section 6254, subdivision (f)(2), about the temporal and substantive scope of disclosure that a local law enforcement agency must make under the CPRA: (1) Whether the Department adequately responded to the request by supplying its summary Calls for Service reports, in light of any applicable exemptions from disclosure of records or information; and (2) whether the Department was justified in denying Fredericks the requested access to information from "complaints and/or requests for assistance" that was more than 60 days old, that it categorized as "historical" in nature. After review, the Court concluded the trial court's narrow construction of the Department's disclosure duties under the CPRA is incorrect both as to the substantive and temporal limits placed upon them. Accordingly, the Court granted Fredericks' petition and directed the trial court to allow such appropriate further proceedings as will determine the reasonable and appropriate levels of disclosures and the allowable costs.
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