Caldecott v. Super. Ct.Annotate this Case
Real-party-in-interest Newport-Mesa Unified School District denied petitioner John Caldecott’s request to produce certain documents made pursuant to the California Public Records Act. Caldecott worked for defendant as Executive Director of Human Resources. During his tenure, Caldecott filed a complaint with School District against its superintendent, Fred Navarro. Five to six weeks later Navarro terminated Caldecott without cause, which decision School District’s board approved. Caldecott alleges this was in retaliation for his complaints about Navarro’s alleged wrongful conduct. Caldecott filed a petition for writ of mandate in the superior court. After its in camera review of the documents, the court denied the petition, ruling that Caldecott already possessed the documents, making his request moot. The court denied the petition on the further ground the documents were connected to his claim of a hostile work environment, making the documents exempt from disclosure under the CPRA. Caldecott’s petition to the Court of Appeal requested the same documents. He argued the court erred by finding his request was moot. Caldecott also asserted there were several other bases for his complaint against defendant, dealing with alleged improprieties including hiring, salaries, and audit practices, not just a personal claim of a hostile work environment. After review, the Court of Appeal concluded the public interest in disclosure of the documents outweighed any privacy interests and the CPRA required their production. The Court granted the petition and remanded the matter to the superior court to conduct an in camera review of the requested documents to determine if any are protected by the attorney-client privilege. The documents were ordered to be redacted to delete the identities of and personal information about unrelated third parties.