South Coast Newspapers, Inc. v. City of Oceanside

This appeal questions denial of South Coast Newspapers, Inc.’s (South Coast) (the public’s) right to inspect or receive a copy of the police report of an investigation undertaken by an Oceanside police officer in response to oral complaints from Oceanside residents a high school principal had failed to report an incident of child abuse. The trial court declared the report was statutorily protected from disclosure no matter its contents. The court also refused to inspect the report in camera, We hold South Coast (the public) is entitled, pursuant to the California Public Records Act (CPRA), Government Code section 6250 et seq., and American Civil Liberties Union Foundation v. Deukmejian (1982) 32 Cal.3d 440 [ 186 Cal.Rptr. 235 , 651 P.2d 822 ], to receive a copy of the report upon request and after the following trial court determinations: (1) no confidential sources will be revealed as a result of the report’s release; (2) disclosure will not interfere with enforcement proceedings; (3) no person will be deprived of a fair trial; (4) release of the report will not constitute an unwarranted invasion of personal privacy; (5) secret police investigative techniques or…