Sacramento Television Stations Inc. v. Superior Court

Summary

The California Court of Appeal reviews a writ proceeding concerning whether the City of Roseville was required under the California Public Records Act to disclose additional body-camera, dashboard-camera, and other recordings depicting a police shooting. The court holds that the superior court correctly determined that more disclosure was required under Government Code section 7923.625, but that the finding that disclosure would substantially interfere with an active investigation was not supported by substantial evidence. The court vacates the ruling and directs the superior court to conduct further proceedings, including an in camera review, to determine the extent of disclosure required.

Holdings

1. Government Code section 7923.625, subdivision (e)(1), requires disclosure of more than recordings limited to the seconds immediately before and after a peace officer's firearm discharge. Recordings must include sufficient surrounding context to permit a viewer to fully, completely, and accurately comprehend the events captured.
2. The superior court's finding that additional disclosure would substantially interfere with an active investigation was not supported by substantial evidence.
3. Under section 7923.625, subdivision (b)(1), an agency may alter a recording through redaction, blurring, or audio distortion to protect a depicted person's privacy, but may not withhold the entire recording under that provision merely because privacy interests are implicated. Complete withholding is governed by subdivision (b)(2) and requires a showing that redaction cannot adequately protect the privacy interest and that the interest outweighs disclosure.
4. The superior court must conduct further proceedings, including an in camera examination of the City's unedited recordings, to determine the precise amount of additional disclosure required.

Questions Presented

1. Whether Government Code section 7923.625, subdivision (e)(1), requires disclosure of more than the brief recordings depicting the seconds immediately before and after officers discharged firearms at a person.
2. Whether the City established by clear and convincing evidence that additional disclosure would substantially interfere with an active investigation under Government Code section 7923.625, subdivision (a)(2).
3. Whether the City could rely on privacy redaction under section 7923.625, subdivision (b)(1), to withhold additional recordings in their entirety.
4. Whether the superior court must conduct an in camera review to determine the extent of additional disclosure required.

Disposition

vacated