Versaci v. Superior Court was a case before California's Fourth District Court of Appeal in 2005 concerning the release of personal performance goals of a school superintendent.
This case established the use of federal precedent for determining whether files in personal folders are subject to exemption.
- In May 2001 the Palomar Community College District hired Dr. Amador as the new superintendent. The contract required a yearly performance evaluation based on established personal goals.
- The personal goals were established during a closed meeting between the district and Amador in June 2002
- Versaci made a public records request in June 2003 for the goals established during the closed meeting.
- The district denied the request claiming that the document fell under privacy exemptions within the California constitution and the California Public Records Act.
- Versaci filed a lawsuit with the superior court attempting to compel the district to release the documents arguing that the goals were terms of Amador's contract and were thus subject to public records requests and not private information.
- The court ruled in favor of the district.
- Shortly after the ruling, on November 13, 2003 Dr. Amador announced her retirement effective July 1, 2004.
- Versaci appealed the decision.
Ruling of the court
The superior court ruled in favor of the district declaring the records to be exempt based on statute 6254(c) because the records were of a personal nature and held within a personal file.
The Court of Appeals ruled in favor of the district, ordering the documents exempt from public records requests.
The court first held, counter to Versaci, that the goals were not part of the contract merely because the contract mentioned them, but were in fact external to the contract and part of the employee's personal file. The court then proceeded to cite federal law in order to establish whether or not the documents fell under the privacy exemption found in statute 6254(c).
Federal cases outline the following three step deliberation process for determining whether records fall under the exemption preventing the release of personal information:
1.) Do the records constitute a personal file?
2.) Would disclosure constitute an unwarrented invasion of privacy?
3.) Does the public interest in disclosure outweigh the harm to the individuals personal privacy.
Based on these criteria the court ruled that the document was in fact a personal file and its release would constitute an unwarranted invasion of privacy and run counter to the intention of the act. It further determined that any public interest in the file was moot, due to Dr. Amador's announced retirement. Based on these facts, the court ruled in favor of the district and awarded the district attorney fees and rendered the documents exempt.
- ↑ 1.0 1.1 1.2 1.3 Ruling of the court