State Department of Public Health v. Superior Court
60 Cal. 4th 940
| Cal. | 2015Background
- The Center for Investigative Reporting requested under the Public Records Act copies of all DPH citations (2002–2011) issued to seven state-owned long‑term care facilities; DPH produced heavily redacted citations.
- The Long‑Term Care Act (Health & Safety Code) requires DPH citations to be in writing, to describe violations with particularity, to make citations public records, and to redact patient names (but otherwise disclose detailed facts, including factors DPH considered in setting penalties).
- The Lanterman Act (Welf. & Inst. Code §§ 5328, 4514) broadly makes "all information and records obtained in the course of providing services" to mentally ill or developmentally disabled persons confidential, with enumerated exceptions.
- DPH redacted citation details relying on Lanterman confidentiality provisions; the Center sued in superior court for disclosure under the Public Records Act.
- The trial court ruled Long‑Term Care Act controlled (more specific and later) and ordered disclosure; the Court of Appeal partially granted relief by attempting to harmonize the statutes and prescribing a tailored redaction scheme; this Court granted review.
- The California Supreme Court reversed the Court of Appeal, holding the Long‑Term Care Act governs and citations must be disclosed subject only to the specific redactions mandated by that Act (primarily patient names).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does §5328 apply to information in DPH citations (i.e., are citations "obtained in the course of providing services")? | The Lanterman confidentiality statute does not cover DPH investigative citations because citations are not "services." | §5328 covers records used by DPH because investigators rely on facility service records; those records are confidential. | Held: §5328 applies; records used in DPH investigations derive from information "obtained in the course of providing services." |
| Can the Long‑Term Care Act and the Lanterman Act be harmonized so both apply? | Center: Long‑Term Care Act is specific and requires disclosure; harmonization is unnecessary because Long‑Term Care Act controls. | DPH/Court of Appeal: Statutes share purposes and can be harmonized by redacting only information inconsistent with Lanterman confidentiality. | Held: The Court of Appeal misapplied harmonization; the statutes conflict and cannot be reconciled by judicially crafting a compromise. |
| If irreconcilable, which statute prevails: the Long‑Term Care Act (later, specific to citations) or the Lanterman Act (general confidentiality)? | Center: Long‑Term Care Act is more specific to DPH citations and later enacted, so it prevails as an exception to §5328. | DPH: §5328 is the more specific rule for records of mentally ill/developmentally disabled persons and should limit disclosure; recent amendments show legislative intent to keep confidentiality. | Held: Long‑Term Care Act is both more specific re: citations and later enacted; it creates a limited exception to §5328. Citations must be public subject only to the redactions the Long‑Term Care Act itself mandates (e.g., patient names). |
| Remedy / scope of disclosure required for existing redacted citations | Center: Full disclosure of citation contents consistent with Long‑Term Care Act (only patient names redacted). | DPH: broader redactions permitted under §5328; Court of Appeal scheme allowed selective redactions. | Held: Reverse Court of Appeal; remand with instruction to deny DPH's petition. Disclose citations except for those redactions expressly required by the Long‑Term Care Act. |
Key Cases Cited
- Kizer v. County of San Mateo, 53 Cal.3d 139 (explaining DPH duties under the Long‑Term Care Act)
- Sorenson v. Superior Court, 219 Cal.App.4th 409 (interpreting §5328 disclosure exceptions)
- Tarasoff v. Regents of University of California, 17 Cal.3d 425 (discussing limits of confidentiality claims)
- Rojas v. Superior Court, 33 Cal.4th 407 (rejecting implied exemptions when statute specifies exemptions)
- Pacific Palisades Bowl Mobile Estates, LLC v. City of Los Angeles, 55 Cal.4th 783 (statutory harmonization principles)
- Collection Bureau of San Jose v. Rumsey, 24 Cal.4th 301 (later enactments and specificity rules for conflicting statutes)
- People v. Gilbert, 1 Cal.3d 475 (special statute construed as exception to general statute)
- Albertson v. Superior Court, 25 Cal.4th 796 (legislative intent and effect of subsequent amendments)