A.C. v. Cortez

Summary

The Ninth Circuit affirmed dismissal of a § 1983 action alleging that county attorneys violated minors' privacy rights by reviewing juvenile case files without a court order while defending the county in a prior lawsuit. The court held that *Gonzalez v. Spencer* did not recognize a per se constitutional right to privacy in juvenile records, and even assuming an informational privacy right, the balancing test under *Seaton v. Mayberg* favored the county because its need to access the records for litigation was high and the risk of misuse was low due to attorney confidentiality obligations. Individual defendants were entitled to qualified immunity, and the *Monell* claim failed because there was no underlying constitutional violation.

Holdings

1. Gonzalez did not recognize a per se constitutional right to privacy in juvenile records. It at most assumed some existing right but did not identify a specific constitutional right.
2. Even assuming plaintiffs were entitled to informational privacy, the balancing test shows the County's interest in defending the litigation outweighed plaintiffs' asserted privacy interest. There was no constitutional violation.

Questions Presented

1. Whether Gonzalez v. Spencer recognized a per se constitutional right to privacy in juvenile records that is always violated by third-party access.
2. Whether the County's access to juvenile case files violated plaintiffs' right to informational privacy under the balancing test of Seaton v. Mayberg.
3. Whether the district court properly dismissed the Monell claim against the County.

Disposition

affirmed