Sierra Club v. Superior Court
57 Cal. 4th 157
Cal.2013Background
- Orange County maintains the OC Landbase: a GIS-formatted parcel database (boundaries, parcel numbers, addresses, owner links) used with off-the-shelf GIS software.
- Sierra Club requested the OC Landbase in its native GIS file format under the California Public Records Act (PRA); County offered underlying records in PDF/paper but required a paid license for GIS files.
- County defended its licensing practice by invoking the PRA exclusion for "computer software," which §6254.9(b) states "includes computer mapping systems."
- Superior Court and Court of Appeal accepted County’s view that GIS-formatted OC Landbase is part of a "computer mapping system" and thus not a public record; Sierra Club sought review.
- Supreme Court granted review to decide whether GIS-formatted databases are excluded from the PRA as "computer software" or instead are public records producible in the electronic format held by the agency under §6253.9.
Issues
| Issue | Plaintiff's Argument (Sierra Club) | Defendant's Argument (County) | Held |
|---|---|---|---|
| Whether a GIS-formatted parcel database is "computer software" excluded from the PRA | "Computer software" excludes only programs; the OC Landbase is data (not programs) and thus a public record producible in its native GIS format | "Computer mapping system" includes both mapping software and databases formatted for mapping software, so OC Landbase is excluded from PRA | GIS mapping software is excluded, but GIS-formatted databases like the OC Landbase are not; they are public records producible in the format held by the agency |
| Whether §6253.9(a)(1) requires agencies to release records in the electronic format they hold | Section requires release in the format held; limiting exclusion to software preserves this rule | County argued broad reading of §6254.9 would allow withholding formatted data, undermining §6253.9 | Court construes §6254.9 narrowly (per constitutional access provision) so §6253.9(a)(1) applies to GIS-formatted data; agencies must provide the data in the format they maintain |
| Proper interpretation of "computer mapping systems" in §6254.9(b) (textual/contextual inquiry) | Ordinary meaning of "software" and statutory context show "computer mapping systems" refers to programs/software only | The word "system" and legislative drafting history support including data as part of mapping systems | Text, statutory context, and related provisions indicate "computer mapping systems" covers mapping software but not user data formatted for use with that software |
| Role of constitutional right of access (Prop 59) in statutory construction | Ambiguities must be resolved to maximize public access; limit exemptions | County urged deference to statutory exclusion and legislative intent to allow recoupment | Where ambiguous, constitutional directive requires narrow construction of PRA exceptions; favors disclosure of GIS-formatted databases |
Key Cases Cited
- International Federation of Professional & Technical Engineers, Local 21 v. Superior Court, 42 Cal.4th 319 (recognizes strong public-access policy under the PRA and constitutional amendment)
- Coalition of Concerned Communities, Inc. v. City of Los Angeles, 34 Cal.4th 733 (statutory interpretation principles)
- Curle v. Superior Court, 24 Cal.4th 1057 (read statute as whole; give significance to all words)
- Williams v. Superior Court, 5 Cal.4th 337 (legislature must expressly limit right of access to overcome presumption of disclosure)
- Office of Inspector General v. Superior Court, 189 Cal.App.4th 695 (narrowly construe statutes limiting access; courts should resolve doubts in favor of disclosure)
- County of Santa Clara v. Superior Court, 170 Cal.App.4th 1301 (distinguished; involved different facts/claims about proprietary software vs. data)