Nat'l Lawyers Guild v. City of Hayward, 27 Cal. App. 5th 937

National Lawyers Guild (Guild) requested police records, including body‑worn camera videos, relating to a Berkeley demonstration; City of Hayward produced redacted videos.
City employees spent significant time (≈170 hours across staff) locating, downloading, reviewing, and redacting video footage, using Windows Movie Maker for audio/video redaction.
City invoiced the Guild $2,939.58 for the first production and $308.89 for a subsequent set; the Guild paid both under protest and sued for refund under the California Public Records Act (CPRA).
Trial court held sections 6253(b) and 6253.9(a)(2) do not permit charging requesters for costs of creating a redacted version of an existing public record; it ordered refund.
Court of Appeal reviewed de novo whether Gov. Code §6253.9(b)(2) allows recovery of costs for extracting/redacting exempt material from electronic records and reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §6253.9(b)(2) permits charging a requester for costs of redacting/extracting exempt material from existing electronic records	Guild: “extraction” means compiling/generating new records from data, not redacting an existing record; thus only direct duplication costs allowed	City: redaction of exempt material from electronic files is an "extraction" or requires programming/computer services recoverable under §6253.9(b)(2)	Court: Ambiguity resolved by legislative history and purpose — §6253.9(b)(2) allows recovery of reasonable costs for programming/computer services used to extract/redact exempt material from electronic records; remand to determine recoverable amounts

City of San Jose v. Superior Court, 2 Cal.5th 608 (California Supreme Court) (CPRA access principles; narrow construction of exemptions)
Commission on Peace Officer Standards & Training v. Superior Court, 42 Cal.4th 278 (California Supreme Court) (public must be informed of police activities)
County of Santa Clara v. Superior Court, 170 Cal.App.4th 1301 (Court of Appeal) (interpretation of §6253.9 cost allocation for electronic records)
Fredericks v. Superior Court, 233 Cal.App.4th 209 (Court of Appeal) (§6253.9(b) added to allocate electronic production costs)
State Bd. of Equalization v. Superior Court, 10 Cal.App.4th 1177 (Court of Appeal) (partial disclosure/segregability principles)
Sierra Club v. Superior Court, 57 Cal.4th 157 (California Supreme Court) (limits of relying on legislative history for statutory meaning)