Supreme Court of California
State Department of Public Health v. Superior Court of Sacramento County, S214679
In this case, real party in interest Center for Investigating Reporting (the Center) filed a Public Records Act request pursuant to the Long-Term Care, Health, Safety, and Security Act (the LTC Act) for copies of all the citations issued by petitioner Department of Public Health (DPH) to the facilities that the Center was investigating. In response, the DPH disclosed heavily redacted copies, citing its obligation not to release certain confidential information under Welfare and Institutions Code section 5328. The Court of Appeal issued a writ directing the trial court to vacate its judgment determining that the LTC Act trumped section 5328. The judgment of the Court of Appeal is reversed and remanded with instructions to deny DPH's petition for writ relief, where: 1) the LTC Act's provisions are later-enacted provisions, and they announce with detail and specificity the information that must be included in DPH citations in the public record; 2) the LTC Act is properly construed as a limited exception to section 5328's general rule of patient and resident confidentiality; and 3) DPH citations issued under the LTC Act are public records and must be disclosed to the Center subject only to the specific redactions mandated by the LTC Act.
- Decided 02/19/2015
- Published 02/19/2015
- Supreme Court of California