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California Sheriff's Investigatory Materials Exempt From Production Under Public Records Act

The City of Los Angeles (City) petitioned for review of an appellate order to produce investigative records to Elgin Haynie regarding a traffic stop by a sheriff's deputy. The production ruling was reversed and the records were ruled exempt.

Haynie and three passengers were stopped and Haynie was handcuffed, but released with no charges, after a citizen stated that three armed teenagers entered a blue van. Haynie's request for the reports involving the incident were denied. The sheriff's department claimed that the records were exempt as investigatory materials. His action for the record's production was dismissed. On appeal, the appellate court ordered the production because the likelihood of enforcement had a concrete and definite disposition. The City sought review.

The Supreme Court of California reversed the production ruling and also reversed the order for the sheriff's department to provide a list of potential exempt documents. It was determined that under the State's Public Records Act, investigatory materials produced by a local police agency were exempt from disclosure and warranted no exemption listing. See: Haynie v. Superior Court of Los Angeles County. 26 Cal. 4th 1061, 31 P.3d 760, 112 Cal. Rptr.2d 80 (Cal. 2001).

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Related legal case

Haynie v. Superior Court of Los Angeles County