Los Angeles Unified School District v. Superior Court
175 Cal. Rptr. 3d 90
Cal. Ct. App.2014Background
- LAUSD developed an AGT metric to measure teacher effect on CST scores, publishing school-wide and grade-level AGT data with teachers’ scores redacted by name; the Times sought unredacted teacher-by-name AGT scores and school location codes under CPRA.
- District and UTLA argued disclosure would implicate privacy and disrupt district operations; the trial court found disclosure not exempt under CPRA and ordered release of names linked to AGT scores.
- UTLA intervened, aligning with the District to uphold nondisclosure; the court noted potential harms from disclosure but weighed privacy against public-interest claims.
- The District also sought to withhold 2009–2010 and 2010–2011 AGT data as preliminary drafts or under personnel exemptions, while ultimately redacting names in some disclosures.
- The trial court concluded the catch-all exemption 6255 supported nondisclosure of named AGT scores, and the writ petition was granted; the matter was remanded for consideration of location codes.
- On review, the court conducted a de novo CPRA balancing and, citing City of Long Beach and related authorities, held that the public interest in nondisclosure outweighed any public interest in disclosure for named AGT scores, but remanded for consideration of location codes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether unredacted AGT scores by teacher name fall under CPRA 6255 | Times seeks disclosure of names with AGT scores | District/UTLA urge nondisclosure to protect privacy and district functioning | 6255 requires nondisclosure; public interest does not clearly outweigh privacy/public-operational interests |
| Whether privacy exemption 6254(c) applies to named AGT scores | Privacy interests should yield to public accountability | Scores linked to names invade privacy; exemptions apply | Catch-all 6255 controls; not necessary to decide 6254(c) applicability on record |
| Whether location codes must be disclosed or remanded for separate consideration | Location codes help link AGT to schools for public understanding | Location codes may have different privacy/public-interest implications | Remand to determine propriety of disclosing location codes; separate from named scores |
Key Cases Cited
- Times Mirror Co. v. Superior Court, 53 Cal.3d 1325 (1991) (public access to information under CPRA/FOIA framework; core purpose to shed light on government)
- Braun v. City of Taft, 154 Cal.App.3d 332 (1984) (balancing public and private interests; narrow construction of exemptions)
- City of San Jose v. Superior Court, 74 Cal.App.4th 1008 (1999) (public interest in disclosure must meaningfully illuminate agency duties)
- City of Long Beach v. City of Long Beach, 59 Cal.4th 59 (2014) (contextual balancing under CPRA; differences from incidents involving public safety)
- Commission on Peace Officer Standards & Training v. Superior Court, 42 Cal.4th 278 (2007) (distinguishes between benign public records and sensitive operational disclosures)
- International Federation of Professional & Technical Engineers v. Superior Court, 42 Cal.4th 319 (2007) (public access vs privacy; framework for balancing interests)
- Versaci v. Superior Court, 127 Cal.App.4th 805 (2005) (privacy considerations in CPRA context; not automatically controlling)
- County of Santa Clara v. Superior Court, 170 Cal.App.4th 1301 (2009) (weight of public interests; case-specific balancing)