California Court of Appeal

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City of San Jose v. Superior Court (Smith), H039498

A petition for a writ of mandate filed by defendant-city and city officials challenging the trial court's order that denied their summary judgment motion and granted declaratory relief to plaintiff, who had asserted the right to inspect specified written communications sent or received by public officials and employees on their private electronic devices using their private accounts, is granted, where the California Public Records Act (CPRA) does not require public access to communications between public officials using exclusively private cell phones or e-mail accounts.

Appellate Information

  • Decided 03/27/2014
  • Published 03/27/2014


  • ELIA


  • California Court of Appeal