Michael Manjeet Singh v. Pheiffer, et al.

Summary

The United States District Court for the Eastern District of California partially overruled defendants’ objections based on the official information privilege to producing investigative documents and recordings in a prisoner civil rights action. The court ordered production of specified interview summaries, a photograph, a disability/accommodation summary, and several staff interview recordings, subject to redaction of investigative analyses and personnel information. The court permitted defendants to withhold other inmate interview materials and a recording containing unrelated investigative information.

Holdings

1. The official information privilege is qualified in this federal civil-rights discovery dispute, and its application requires in camera review and balancing the benefits of disclosure against the potential disadvantages.
2. Defendants must produce the interview summaries of Plaintiff and identified CDCR staff, Plaintiff’s photograph, Plaintiff’s disability/accommodation summary, and the audio recordings of interviews with Pinedo, Dillard, Diaz, Vieth, and Fowler, subject to permitted redactions.
3. Defendants may withhold the audio recordings and written summaries of other inmate witnesses, Captain Waddle’s audio recording, institutional analyses and opinions, and CDCR personnel and contact information because the disadvantages of disclosure outweigh their relevance.

Questions Presented

1. Whether the official information privilege required withholding the prison grievance-investigation materials and interview recordings from discovery.
2. Whether the relevance of direct witness accounts, a photograph, and a disability/accommodation summary outweighed the asserted confidentiality, safety, retaliation, and investigative-integrity concerns.
3. Which portions of the investigative materials were subject to production and which could be withheld or redacted.

Disposition

other