Bakersfield City School Dist. v. Superior Court was a case before California's Fourth District Court of Appeal in 2004 concerning access to disciplinary records.
This case defined the criteria for the release disciplinary allegations against government employees as a reasonable degree of reliability so as to potentially confirm the allegation. It also ruled that a true confirmation of allegations or disciplinary action against wrong doing was not required prior to the release of records recording allegations.
- On July 24, 2003, the Bakersfield Californian was forced to file suit for a denied public records request of the records of disciplinary action taken against a school district employee.
- On September 12, 2003 the court issued an order that the documents be released with names and personal information redacted, because the alleged charges were well grounded.
- The school district appealed the ruling.
Ruling of the court
THe court ruled in favor of the newspaper, ordering the records released and affirming the district courts decision.
The court in its ruling relied on American Federation of State etc. Employees v. Regents of University of California which established as precedent the criteria required for determining if alleged disciplinary actions should be released as public records requests. The court tells us that "where complaints of a public employee's wrongdoing and resulting disciplinary investigation reveal allegations of a substantial nature, as distinct from baseless or trivial, and there is reasonable cause to believe the complaint is well founded, public employee privacy must give way to the public's right to know." However, while the school district holds that only allegations that have been disciplined should be considered, per Chronicle Pub. Co. v. Superior Court and City of Hemet v. Superior Court, the Supreme court did not agree and established the precedent that confirmed allegations or disciplinary action are not prerequisites for the release of allegations of misconduct by government employees. The court determined that the only criteria necessary for a court to order the release allegations of misconduct was a reasonable degree of reliability found in the documents making the allegation. Based on this criteria, the court concurred with the district court and ordered the records released.
- ↑ 1.0 1.1 1.2 Ruling of the Court