American Federation of State etc. Employees v. Regents of University of California was a case before the California First District Court of Appeal, Division One in 1978 concerning privacy exemptions within statute 6254(c) of the California Public Records Act.
This ruling affirmed the decision of Chronicle Pub. Co. v. Superior Court, namely, that for records requests of allegations of employee misconduct to be released, the allegation must be both well grounded (but not necesarily proved) and of substantial importance to warrant the public's interest.
- An employee at the University of California, San Fransisco accused her supervisors of financial irregularities. A major investigation followed, which produced an elaborate audit report on the individuals in question, who were not members of the union.
- The union requested a copy of the audit report under the California Public Records Act
- The University rejected the requet based on statute 6254(c).
- The document was released in part and the union filed an appeal requesting the whole document on the grounds that the document relates to the expenditure of public funds which is a critical aspect of any consideration of public interest.
Ruling of the court
The court ruled in favor of University, issuing only a small part of the requested material to the union.
The court began their considerations with a look at Chronicle Pub. Co. v. Superior Court, which ruled that in cases of disciplinary action that may invade privacy, it is important to exempt those allegations which are unfounded and would cause harm to character even if determined to be untrue. The Chronicle court also ruled that in cases where disciplinary action is taken or the charges are proved true, the exemption automatically disappears for even the smallest offense. The court further determined that the release of any allegation prior to confirmation required the content of the allegation to be of a substantially important nature so as to warrant the invasion of privacy. The court examined the document in camera and agreed with the document that a majority of the allegations were unfounded. They ordered the release of records pertaining to any substantial allegations, and the remaining unfounded allegations were ordered exempt from the request.
- ↑ Ruling of the Court