Sacramento County Deputy Sheriffs' Ass'n v. County of Sacramento

In this civil action by county jail employees arising from warrantless video surveillance of a county jail office, plaintiffs—Sacramento County Deputy Sheriffs’ Association (the Association) and Deputy Sheriffs Dennis Prizmich, Scott Eckert, and Ray Roberts—appeal from summary judgment entered in favor of defendants Sacramento County, Sacramento County Sheriff’s Department, Sheriff Glen Craig, Undersheriff Arthur Henrickson, Chief Robert Denham, and Captain Richard McKee. The trial court determined plaintiffs had no reasonable expectation of privacy. Plaintiffs contend summary judgment was improperly granted because the videotaping assertedly (1) violated protections against unlawful search and seizure (U.S. Const., 4th Amend.; Cal. Const., art. I, § 13 ), (2) violated statutory prohibitions against invasion of privacy (Pen. Code, § 632 et seq.), and (3) constituted a tortious intrusion into plaintiffs’ seclusion. We shall affirm the judgment.

Factual and Procedural Background

This dispute involves placement of a video camera in the release office of the county jail.

Between February and April 1993, the main jail division of the Sacramento County Sheriff’s Department…