County of Los Angeles v. Superior Court

Records of organized medical peer review committees are exempt from discovery in a civil action pursuant to Evidence Code section 1157. Section 1157.6 extends the same protection to the quality assurance committees of county-operated mental health facilities. Petitioners, the County of Los Angeles (County), the Los Angeles County Sheriff’s Department (LASD), and Los Angeles County Sheriff Lee Baca, challenge an order of respondent court directing them to produce certain documents generated by the chair of the Quality Assurance Committee for the Jail Mental Health Services Division of the Los Angeles County Department of Mental Health. We hold that the documents are exempt from disclosure under sections 1157 and 1157.6. Accordingly, we grant the petition.

FACTS AND PROCEDURAL HISTORY

In July 2002, Ramon Gavira Camarillo was found hanging in his cell at the Los Angeles County jail, where he was incarcerated after having been arrested for driving under the influence. Plaintiffs, who are Mr. Gavira’s widow and children, contend that during the 72 hours he was in the custody of the Los Angeles County Sheriff, Mr. Gavira was beaten repeatedly by sheriff’s deputies. Plaintiffs…