California Public Records Research, Inc. v. County of Alameda
Annotate this CaseThe Alameda County Clerk-Recorder’s Office processes and maintains public records, including documents affecting real property, business records, and marriage, birth and death certificates, so that copies can be made available when requested. In 2010, Alameda County adopted an ordinance increasing various fees charged by the Office, including an increase of the fee for copies of records from $1.50 per page to $3.50 per page, based on fee studies conducted in 2009-2010. Considering its direct and indirect costs, the total cost to the County to copy a recorded document was calculated at $3.60 per page, 10 cents more than the amount it decided to charge. Fees charged by neighboring counties “ranged from $1.00 per page to $7.00 per page.” Government Code section 27366 provides that the fee “shall be set . . . in an amount necessary to recover the direct and indirect costs of providing the product or service.” California Public Records Research successfully challenged the fee increase. The court of appeal reversed. CPRR failed to establish the County’s calculation of recoverable “indirect costs” violated section 27366. The County did not act arbitrarily or otherwise abuse its discretion when it determined that charging $3.50 per page was necessary to recover the direct and indirect costs of making copies.
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