Edais v. Superior Court of San Mateo County
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Munir, a police officer, confronted Eman, his wife of six months, with his suspicion that she was unfaithful, and stated he intended to seek a divorce. On January 19, Munir discussed this intention with his sister but uncharacteristically failed to respond to multiple voice and text messages over the next 36 hours. On January 21, Eman called 911 to report Munir had hanged himself at home. A forensic audio analysis of the 911 call indicates a third person may have been present. After an autopsy, the Coroner’s Office classified Munir’s death as suicide. His parents arranged for a forensic autopsy review and served California Public Records Act (CPRA) Gov. Code, 7920.000 requests, seeking “all DOCUMENTS received or generated by, or currently in the possession of, the [Coroner’s] Office in connection with the death of Munir Edais,” defining “DOCUMENTS”, to include photographs, video recordings, “and all other electronically stored information.” The Coroner’s Office declined to provide photographs or the full Report because the widow had not consented.
The Superior Court denied Munir's parents relief under the CPRA, but on its “own motion” required the production of the requested photographs and Report, citing Code of Civil Procedure 129(a), The court of appeal reversed. The Superior Court erred in finding that the CPRA request was limited to certain photographs and the Investigation Report and that the records sought are not public records and/or are exempt from CPRA disclosure.
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