Cnty. of L. A. Bd. of Supervisors v. Superior Court of L. A. Cnty.
Opinion
Lead Opinion
Aldrich, J.
*1269 This writ proceeding returns to us on remand from the California Supreme Court. Real parties in interest the ACLU of Southern California and Eric Preven (collectively the ACLU) sought disclosure under the California Public Records Act (PRA) of billing invoices sent to petitioner the County of Los Angeles Board of Supervisors (the County) by its outside attorneys. The superior court granted the ACLU's petition for writ of mandate and compelled disclosure, and the County challenged that decision via a petition for a writ of mandate in this court. In our original opinion, we concluded that the subject invoices were confidential communications within the meaning of Evidence Code section 952, and therefore were protected by the attorney-client privilege and exempt from disclosure under Government Code section 6254, subdivision (k). Accordingly, we granted the County's writ petition. The California Supreme Court granted review, reversed our decision, and remanded for further proceedings. ( Los Angeles County Bd. of Supervisors v. Superior Court (2016) 2 Cal.5th 282 , 300, 212 Cal.Rptr.3d 107 , 386 P.3d 773 ( Los Angeles County ).) Applying the analysis mandated by Los Angeles…