Bondgraham v. Superior Court of Alameda CountyAnnotate this Case
In 2019, two Oakland journalists filed requests with the Oakland Police Department under the California Public Records Act (CPRA) (previously Gov. Code 6250, now 7921.000), including for information regarding the “Celeste Guap” scandal, which involved several Oakland police officers who had sex with Guap while she was underage. The trial court ordered Oakland to produce documents responsive to those requests. Oakland produced a redacted version of the internal affairs investigation report.
The court of appeal agreed that some of the challenged redactions were not permitted under the statute. In 2018 Senate Bill 1421 amended Penal Code section 832.7 to require public access to certain records of police misconduct and use of force. The trial court improperly permitted Oakland to redact certain information under section 832.7(b)(4) and (b)(5), including the Guap report’s training and policy recommendations; witness statements containing general information about Guap and her social-media use (without any information about allegations of misconduct against any officer); screenshots of Guap’s Facebook profile; and large portions of her statements to investigators. Redaction of witness-officer’s names or other identifying information from the interview summaries is not appropriate under section 832.7(b)(6)(B) in order to “preserve the anonymity of . . . witnesses.”