Vincent Alex DeLeon v. Steven Santiago

Summary

The court partially overruled Defendant Steven Santiago’s objections to producing documents and recordings based on the official information privilege in a 42 U.S.C. § 1983 excessive-force action. The court ordered production of specified witness statements, interview summaries, medical and disciplinary records, audio-recorded interviews, and portions of body-worn-camera footage, subject to redactions. It upheld objections to investigative analyses, hiring and closure documents, personnel information, footage of a nonparty inmate’s unclothed search, and control-booth footage.

Holdings

1. The official information privilege is qualified, and a court must conduct an in camera review and balance the requesting party's need for relevant evidence against the government's asserted risks of disclosure. Here, the balance favored production of specified direct evidence and witness accounts relevant to the excessive-force claim.
2. Santiago must produce the specified portions of the administrative investigation materials, witness narratives and interview summaries, identified exhibits, audio-recorded interviews, and the body-camera footage beginning at 9:34:17, with permitted redactions for institutional analyses, investigative procedures, and personnel information.
3. The court sustained the objections to producing the first 1 minute and 18 seconds of the specified body-camera footage, the control-booth footage, institutional analyses and opinions, hiring-review and closing documents, and CDCR personnel and contact information.

Questions Presented

1. Whether the official information privilege required withholding all or portions of the investigative reports, witness materials, audio recordings, and body-camera footage.
2. Whether the direct evidence and witness accounts relevant to DeLeon's excessive-force claim should be produced after in camera review, subject to redactions.
3. Whether footage depicting a nonparty inmate's unclothed search and footage of a prison control booth should be withheld because of privacy and institutional-security concerns.

Disposition

other