Pack

We address the construction and application of Welfare and Institutions Code section 827, subdivision (a)(2), which deals with the public disclosure of the juvenile records of deceased dependent minors. We hold that (1) redaction, from the records pertaining to a deceased child, of information about a living child is not the sole statutory means by which the juvenile court may protect the interests of the living child; (2) a finding by the juvenile court that disclosure of information relating to the deceased child is “detrimental to the safety, protection, or physical, or emotional well-being of’ (ibid.) a living child is sufficient to justify withholding some or all of the information about to the deceased child and implies a finding that redaction would be insufficient to protect the interests of the living child; (3) substantial evidence is the proper standard for the review of such express and implied findings by the juvenile court; and (4) the juvenile court’s order in this case refusing to release any information about the deceased child is supported by substantial evidence.

Summary of Facts and Proceedings Below

On February 10, 2000, Jaime M., a minor and a…