Dixon
Dixon v. Superior Court
Opinion
Opinion
Davis, J.
In this California Public Records Act case (CPRA; Gov. Code, § 6250 et seq.), we hold that coroner and autopsy reports that constitute investigations of a suspected homicide death — in which the prospect of criminal law enforcement proceedings is concrete and definite — are public records that are exempt from disclosure under Government Code section 6254, subdivision (f) (hereafter section 6254(f)), of the CPRA. As relevant here, that subdivision exempts from public disclosure “investigatory . . . files compiled by any . . . local agency for . . . law enforcement. . . purposes.”
Background
The bullet-riddled body of Elizabeth Cloer was found in an open field in El Dorado County in June 1971. Thirty-one years later, DNA analysis of evidence from the scene produced a DNA profile apparently matching that of Phillip Arthur Thompson. In April 2008, Thompson was convicted of murdering Cloer.
Kathryn J. Dixon, the petitioner here, is a news reporter who covered the Thompson murder trial and intends to write a book about it. Pursuant to the CPRA, Dixon requested, before trial had commenced, the complete coroner and autopsy reports regarding Cloer from the El Dorado County…