Doe v. County of Orange

CourtCalifornia Court of Appeal
DecidedSeptember 2, 2025
DocketG064562
StatusPublished

This text of Doe v. County of Orange (Doe v. County of Orange) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doe v. County of Orange, (Cal. Ct. App. 2025).

Opinion

Filed 9/2/25

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

JOHN DOE (No. 0136),

Plaintiff and Appellant, G064562

v. (Super. Ct. No. 30-2022-01286908)

COUNTY OF ORANGE et al., OPINION

Defendants and Respondents.

Appeal from a judgment of the Superior Court of Orange County, Richard Oberholzer, Judge. (Retired judge of the Kern Sup. Ct. assigned by the Chief Justice pursuant to art. VI, § 6 of the Cal. Const.) Reversed and remanded with directions. Adkisson Pitet and Carl A. Berthold, Jr., for Plaintiff and Appellant. Gutierrez, Preciado & House, Calvin House and Natalia Anthony for Defendants and Respondents. * * * Welfare and Institutions Code section 5328 makes “all information and records obtained in the course of providing services . . . to either voluntary or involuntary recipients . . . confidential.” (Welf. & Inst. Code,1 § 5328, subd. (a).) Section 5330 authorizes a person who received such services to bring an action against anyone who unlawfully disclosed such records. (§ 5330, subd. (a).) If the records were negligently disclosed, the statute awards the aggrieved party $1,000 and actual damages. (§ 5330, subd. (b)(1) & (2).) However, if the records were “willfully and knowingly” disclosed, the statute awards the aggrieved party the greater of $10,000 or three times the amount of the actual damages. (§ 5330, subd. (a)(1) & (2).) Robert G. Reyna (Reyna), who worked for the Orange County Sheriff’s Department, unlawfully disclosed John Doe’s (Doe) confidential record to Doe’s sister and her attorney who used it to threaten Doe to dismiss a lawsuit Doe brought against his sister. Doe brought an action against Reyna and the County of Orange (the County) in which a jury found Reyna willfully and knowingly disclosed the record. However, the jury apportioned 25 percent of Doe’s damages to Doe’s sister and her attorney based on their conduct. The trial court then granted Reyna and the County’s motion for partial judgment notwithstanding the verdict ruling that there was not substantial evidence to support the finding of willfulness; the court, as a result, did not treble damages. The trial court apportioned both economic and noneconomic damages and entered a judgment in favor of Doe. Doe appeals arguing the trial court erred in concluding there was not substantial evidence to support the jury’s finding and in apportioning

1 All further statutory references are to the Welfare and Institutions Code unless otherwise stated.

2 damages. On appeal, all parties agree Reyna unlawfully disclosed the confidential record. But the parties disagree over what it means to “willfully and knowingly” disclose confidential records within the meaning of section 5330. As we explain, it means Reyna intentionally released Doe’s confidential record to a person Reyna knew was not entitled to the record and the disclosure was otherwise unlawful. We then conclude the trial court erred in granting Reyna and the County’s motion for partial judgment notwithstanding the verdict. Last, although Reyna willfully and knowingly released Doe’s confidential record, he was not an intentional tortfeasor. Reyna and the County, thus, were entitled to have Doe’s noneconomic damages apportioned to other tortfeasors—but not Doe’s economic damages. FACTS In 2018, Doe was placed on an involuntary 72-hour hold pursuant to section 5150. The Orange County Sherriff’s Department generated a confidential record of the incident. In 2021, a dispute arose between Doe and his sister over their father’s estate. Doe filed a lawsuit for elder abuse against his sister. During the lawsuit, Doe learned his sister’s attorney had obtained a copy of the 2018 confidential record. The attorney threatened to disclose the record unless Doe dismissed the lawsuit. Doe believed his sister and her attorney were blackmailing him which made him fearful. Reyna testified he worked for the sheriff’s department as an office specialist where he reviewed incoming requests for information and determined whether to release such records. In 2021, Reyna received a request for two reports from Doe’s sister. The first was a report of a welfare check in which Doe’s sister was the caller, and the second was for the confidential record. Doe’s sister was entitled to the welfare check report, but

3 not the confidential record. Reyna knew Doe’s sister was not entitled to the confidential record, but he released it to her anyway. Reyna made “a judgment call”; he believed Doe’s sister was “concerned” about Doe and testified that his “heart got in the way.” The parties agreed Reyna’s disclosure was unlawful. The issue for the jury was whether the disclosure was willful or negligent. The court instructed the jury that the disclosure was “‘wil[l]ful’” if Reyna “knew of his legal obligations and intentionally declined to follow them. However, a violation is not willful if you find that Robert Reyna reasonably and in good faith believed that the facts did not require him to comply . . . .” The trial court also instructed the jury that it could apportion a percentage of Doe’s damages to Doe’s sister and her attorney if they were “at fault,” and if this fault “was a substantial factor in causing John Doe’s harm.” The jury found Reyna willfully disclosed the confidential record, but determined Doe’s sister and her attorney were responsible for 25 percent of Doe’s damages. The jury awarded Doe $29,000 in economic damages and $40,000 in noneconomic damages. Reyna and the County filed a motion for partial judgment notwithstanding the verdict. They claimed there was not substantial evidence to support the jury’s determination that the disclosure was willful and knowing. The trial court granted the motion and therefore did not award treble damages. Instead, the trial court ruled the entire $69,000 was subject to apportionment and entered a judgment for $51,750 (75 percent of $69,000) against Reyna and the County.

4 DISCUSSION I. THERE WAS SUBSTANTIAL EVIDENCE REYNA’S DISCLOSURE OF DOE’S CONFIDENTIAL RECORD WAS WILLFUL AND KNOWING Doe contends the trial court erred in granting Reyna and the County’s motion for partial judgment notwithstanding the verdict. The parties disagree as to what willfulness means within the context of section 5330. Doe believes it means ‘“a purpose or willingness to commit the act or engage in the conduct in question.’” Reyna and the County argue willfulness requires knowledge harm will follow or at least reckless disregard of a risk of harm. As we explain, Doe’s interpretation is closest. A. Standard of Review “‘“A motion for judgment notwithstanding the verdict may be granted only if it appears from the evidence, viewed in the light most favorable to the party securing the verdict, that there is no substantial evidence in support. [Citation.] [¶] . . . As in the trial court, the standard of review [on appeal] is whether any substantial evidence—contradicted or uncontradicted—supports the jury’s conclusion.””’ (Webb v. Special Electric Co., Inc. (2016) 63 Cal.4th 167, 192.) In reviewing the evidence, we draw all reasonable inferences in Doe’s favor and disregard evidence that conflicts with any evidence which supports the verdict. (Ibid.) “Our determination as to the requisite substantial evidence is de novo.” (Lurner v. American Golf Corp. (2023) 97 Cal.App.5th 121, 133.) We similarly review legal issues, such as the interpretation of a statute, de novo. (Ibid.) B. Willfulness Denotes Intentionally Committing the Act in Question Section 5330 does not define the phrase “willfully and knowingly.” Therefore, we must turn to principles of statutory construction to

5 determine its meaning.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Freeman & Mills, Inc. v. Belcher Oil Co.
900 P.2d 669 (California Supreme Court, 1995)
Goodhew v. Industrial Accident Commission
320 P.2d 515 (California Court of Appeal, 1958)
Cedars-Sinai Medical Center v. Superior Court
954 P.2d 511 (California Supreme Court, 1998)
Soule v. General Motors Corp.
882 P.2d 298 (California Supreme Court, 1994)
Moore v. Conliffe
871 P.2d 204 (California Supreme Court, 1994)
Calvillo-Silva v. Home Grocery
968 P.2d 65 (California Supreme Court, 1998)
McCollum v. CBS, INC.
202 Cal. App. 3d 989 (California Court of Appeal, 1988)
Brown v. State Department of Health
86 Cal. App. 3d 548 (California Court of Appeal, 1978)
Taylor v. John Crane, Inc.
6 Cal. Rptr. 3d 695 (California Court of Appeal, 2003)
Wilson v. Ritto
129 Cal. Rptr. 2d 336 (California Court of Appeal, 2003)
Kwan v. Mercedes-Benz of North America, Inc.
23 Cal. App. 4th 174 (California Court of Appeal, 1994)
Devereaux v. Latham & Watkins
32 Cal. App. 4th 1571 (California Court of Appeal, 1995)
Willard v. Caterpillar, Inc.
40 Cal. App. 4th 892 (California Court of Appeal, 1995)
Aguilar v. Atlantic Richfield Co.
24 P.3d 493 (California Supreme Court, 2001)
Myers v. Philip Morris Companies, Inc.
50 P.3d 751 (California Supreme Court, 2002)
Silberg v. Anderson
786 P.2d 365 (California Supreme Court, 1990)
In Re Qawi
81 P.3d 224 (California Supreme Court, 2004)
Vollaro v. Lispi
224 Cal. App. 4th 93 (California Court of Appeal, 2014)
Falcon v. Long Beach Genetics, Inc.
224 Cal. App. 4th 1263 (California Court of Appeal, 2014)
Kenne v. Stennis
230 Cal. App. 4th 953 (California Court of Appeal, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Doe v. County of Orange, Counsel Stack Legal Research, https://law.counselstack.com/opinion/doe-v-county-of-orange-calctapp-2025.