Coronado Police Officers Association v. Carroll was a case before California's Fourth District Court of Appeal in 2003 concerning access to a database created by the defendant as the San Diego County Public Defender.
This case established that the records of the public defender with regard to its endeavors to defend accused individuals are private due to the private nature of the litigation and to insure the effectiveness of public defense.
- The Public Defender is an agency within San Diego County, which defends individuals accused of crimes who cannot afford their own lawyers.
- The office of the Public Defender recently collected its entire case record since 1988 into an electronic database which allowed lawyers within the office to search the cases and use them for research to better defend current clients.
- A number of police associations discovered the existence of the database and submitted a public records request to review the document arguing that it wanted to search the document for records of police officers, insure the accuracy of the database, and insure that it was not an unnecessary collection of personal information that would violate California's constitution.
- The Public Defender denied the request and the police associations filed suit.
- The trial court ruled in favor of the Public Defender and the police associations appealed.
Ruling of the court
The trial court ruled in favor of the Public Defender stating that the database in question was not a public record.
The court of appeals ruled in favor of the Public defender.
The court of appeals agreed with both the trial court and the public defender that the document was not a public record because its main function of defending criminals was a private venture and not part of public duty. Further, this information must be kept private so that the Public Defender can continue to use it to develop litigation strategies without the fear of those strategies already being known. The court further found that California's catch all exemption of statute 6255 applied. The court disagreed with the police association's arguments for the public interest and determined:
- that the document was a necessary collection of information in line with the constitution
- that the records of police officers are maintained elsewhere to prevent illegal inclusion of material as evidence and
- that inaccurate information is never useful to the public but may be useful to the attorney's prosecuting individuals cases.
Further, the release of the information would result in a huge detriment to the public interest in that the state would no longer be able to provide effective public defenders for accused criminals who had a right to legal aid but could not afford it. They thus ruled in favor of the Public Defender and ordered the documents exempt for both reasons.
- ↑ 1.0 1.1 1.2 Ruling of the Court (dead link)