Williams v. Superior Court was a case before the California Supreme Court in 1993 concerning records requests for law enforcement investigation files.
This case established that federal FOIA law and litigation can only be used to clarify the California Public Records Act and not to add or detract from the act.
- On August 22, 1990, police searched the home of Daniel Morgan, who was arrested during the search. The search came under public scrutiny when Morgan alleged that he was beaten and injured during the raid. The Sheriff's department conducted a number of investigations, finally filing a lawsuit against one of the alleged deputy Sheriffs. The deputy Sheriff was tried and acquitted.
- The Daily Press, a local newspaper, submitted a public records request for all documents associated with the internal investigations of the Sheriff's Office concerning the events at Morgan's home.
- The Sheriff rejected the request based on the exemption for police internal investigations found in the California Penal Code and the portions of the California Public Records Act which protect personal privacy.
- The newspaper filed suit in superior court seeking to compel the Sheriff's office to release the documents arguing that the Penal code only applied to discovery in court cases and the protections for personal privacy did not apply because the individuals in question were found guilty and punished.
- In the trial, the sheriff's office altered their claim and alleged that the documents were exempt based on 6254(f) of the public records act which protected police investigation files.
- The trial court delivered a split decision, granting access to 10 whole documents, parts of 28 others, and exempting a full 29 documents. The court, however, failed to rule on all the documents present.
- Both parties appealed to the California Court of Appeals, which remanded the decision to trial court adding two stipulations taken from federal statutes and practices.
- The Sheriff's office appealed the decision of the court of appeals.
Ruling of the court
The trial court delivered a partial ruling, ordering some of the documents disclosed and others exempt. The court of appeals remanded the decision to the trial court after adding the stipulations present in Federal FOIA law, statute 5 U.S.C. 552(b)(7), which protect police records if:
1.) The release would interfere with trials
2.) Deprive a person of a fair trial
3.) Invade privacy
4.) Disclose confidential sources
5.) Would disclose law enforcement investigative techniques
6.) Would endanger any individual
The court of appeals determined that investigatory files are only exempt if they are part of a pending investigation or if they meet one of the above 6 criteria.
The Supreme Court overturned the decision of the Court of Appeals and remanded the decision to superior court with orders to review the documents again.
The Supreme Court determined that the intent of the legislature was to protect police files and that the Court of Appeals had erred in including federal criteria on the California law, thus stripping those files of their intended protection. The court also determined that the California legislature had not intended to place a time limit on the exemption for records. Thus, the Court of Appeals decision to include the federal time limit was ill founded as well. Based on these facts, the Supreme Court remanded the decision to the superior court with the order to only consider the statute as it reads in California law.