Sierra Club v. Superior Court

Like many counties in California, Orange County (the County) maintains a large database of information about land parcels in a geographic information system (GIS) file format. With this database, called the “OC Landbase,” a user with appropriate software can create a layered digital map containing information for over 640,000 specific parcels of land in Orange County, including geographic boundaries, assessor parcel numbers, street addresses, and links to additional information on the parcel owners. The issue in this case is whether the OC Landbase is subject to disclosure in a GIS file format at the actual cost of duplication under the California Public Records Act (Gov. Code, § 6250 et seq.) or whether, as the County contends, it is covered by the statute’s exclusion of “[c]omputer software” (Gov. Code, § 6254.9, subd. (a))—a term that “includes computer mapping systems” (id., § 6254.9, subd. (b))—from the definition of a public record. We hold that although GIS mapping software falls within the ambit of this statutory exclusion, a GIS-formatted database like the OC Landbase does not. Accordingly, such databases are public records that, unless otherwise exempt, must be…