In re Walter A.C. CA1/1

Opinion

Filed 9/11/26 In re Walter A.C. CA1/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION ONE

In re WALTER A.C., a Person Coming Under the Juvenile Court Law. THE PEOPLE, Plaintiff and Respondent, v. WALTER A.C., A174048 Defendant and Appellant;

(San Francisco City & County Super. Ct. No. JW24-6247)

SHANNON COX, Petitioner and Respondent.

MEMORANDUM OPINION1

Defendant Walter A.C. appeals from the juvenile court’s order granting Shannon Cox’s petition for access to Walter’s juvenile case file pursuant to Welfare and Institutions Code2 section 827. We reverse.

1 We resolve this case by memorandum opinion (Cal. Stds. Jud. Admin.,

§ 8.1) and recite only those facts necessary to resolve the limited issue before us (People v. Garcia (2002) 97 Cal.App.4th 847, 851).

2 Undesignated statutory references are to the Welfare and Institutions

Code.

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Walter is the subject of section 602 juvenile wardship proceedings initiated in 2024 when he was 17 years old. On June 5, 2025, the juvenile court conducted a disposition hearing and made dispositional findings. Three weeks later, Cox filed a form petition for access to Walter’s juvenile case file pursuant to section 827. In identifying the records she wanted, Cox stated, “Requesting records pertaining to sentencing and sentencing guidelines. [¶] Walter was recently sentenced or seen in court 6/5/25 for his arrest in April 2025 by SFPD.” In the section of the form beginning “I need the records because (describe in detail; attach more pages if you need more space),” Cox wrote, “Records are being requested due to an ongoing FBI investigation.”3 She provided no further information. Walter, through his counsel, objected to the release of records. His sister also objected.

On August 5, 2025, the juvenile court filed an order on Cox’s petition stating it would review the juvenile case file and objections. On August 14, the court filed an order granting the petition. The form order checked the box stating, “The petitioner has shown by a preponderance of the evidence that access to records is necessary and that records have substantial relevance to the legitimate needs of the petitioner. The court has balanced these needs with the child’s best interest. The court finds that the need for access outweighs the policy considerations favoring confidentiality of juvenile records.” The court allowed only the following records to be disclosed: the minutes of the disposition hearing conducted on June 5, 2025. Walter timely

3 In his opening brief, Walter states that Cox is an employee of the

Federal Bureau of Investigation (FBI). We observe that nothing in the record identifies who Cox is. In her petition, she provided a mailing address but did not identify any employer/entity name. She did not state that she is an FBI employee.

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appealed. We granted Walter’s petition for writ of supersedeas and stayed enforcement of the juvenile court’s order pending resolution of the appeal.

Walter argues the juvenile court abused its discretion in granting Cox’s petition for access under section 827. No respondent’s brief was filed,4 therefore we decide the appeal on the record and Walter’s opening brief. (Cal. Rules of Court,5 rule 8.220(a)(2).)

The Legislature has expressly stated that “juvenile court records, in general, should be confidential.” (§ 827, subd. (b)(1).) Section 827 sets forth detailed provisions to protect this confidentiality. (J.E. v. Superior Court (2014) 223 Cal.App.4th 1329, 1337.) It specifies who is authorized to inspect case files without a court order. (§ 827, subd. (a)(1); J.E., at p. 1337.) “Section 827 also contains provisions that permit unauthorized persons to directly petition the juvenile court for access to the confidential records. (§ 827, subd. (a)[(3)]; . . . .) Under section 827 the juvenile court has ‘exclusive authority to determine whether and to what extent to grant access to confidential juvenile records’ to unauthorized persons. [Citation.] This statutory scheme reflects a legislative determination that the juvenile court has ‘both the “ ‘sensitivity and expertise’ to make decisions about access to juvenile records.” ’ ” (J.E., at p. 1337, fn. omitted.)

Rule 5.552 dictates the procedure for, and judicial review of, a request to access a juvenile case file pursuant to section 827. The petitioner must

4 Cox did not file a respondent’s brief. Cox was served by mail at the address she listed in her petition with Walter’s notice of appeal, his opening brief, and this court’s July 8, 2026 correspondence notifying her that she had not filed a respondent’s brief. The People filed a response to Walter’s petition for writ of supersedeas stating they did not take a position on Cox’s petition in the juvenile court and they decline to take a position in this court.

5 Further references to rules are to the California Rules of Court.

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identify the “specific file sought” and “describe in detail the reasons the file is being sought and its relevance to the proceeding or other purpose for which petitioner wishes to inspect or obtain the file.” (Rule 5.552(a)(1), (2).) The petitioner bears the burden to show good cause justifying access to the records. (Rule 5.552(c)(1), (2).) If the petitioner does not show good cause, the court must deny the petition summarily. (Rule 5.552(c)(1).) If there is good cause, whether the court conducts a hearing, if the court determines that there may be information or documents in the records sought to which the petitioner may be entitled, the court must conduct an in camera review of the case file and any objections. (Rule 5.552(c)(2), (3).) In determining whether to authorize disclosure, the court “must balance the interests of the child . . ., the interests of the petitioner, and the interests of the public” (rule 5.552(c)(4)) and may permit access “only insofar as is necessary, and only if petitioner shows by a preponderance of the evidence that the records requested are necessary and have substantial relevance to the legitimate need of the petitioner” (rule 5.552(c)(6)). To grant the petition, “the court must find that the need for access outweighs the policy considerations favoring confidentiality of the juvenile . . . case file.” (Rule 5.552(c)(5).)

“Generally, a juvenile court has broad and exclusive authority to determine whether and to what extent to grant access to confidential juvenile records pursuant to section 827. [Citations.] Review of a juvenile court’s decision to release juvenile records under section 827 is for abuse of discretion.” (In re Elijah S. (2005) 125 Cal.App.4th 1532, 1541.) “The abuse of discretion standard is not a unified standard; the deference it calls for varies according to the aspect of a trial court’s ruling under review. The trial court’s findings of fact are reviewed for substantial evidence, its conclusions of law are reviewed de novo, and its application of the law to the facts is

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reversible only if arbitrary and capricious.” (Haraguchi v. Superior Court (2008) 43 Cal.4th 706, 711–712, fns. omitted.) Here, the juvenile court applied the law dictating petitions to access juvenile case files to undisputed facts. Therefore, we review whether its decision was arbitrary and capricious.

While taking into account the deferential standard of review, we conclude the juvenile court abused its discretion in granting Cox’s petition. The petition lacks any details demonstrating good cause to grant the request. (See rule 5.552(c)(1).) It also fails to demonstrate that Cox showed “by a preponderance of the evidence that the records requested are necessary and have substantial relevance to the legitimate need of the petitioner.” (Rule 5.552(c)(6), italics added.) In explaining the reason Cox needs the records, the petition merely states, “Records are being requested due to an ongoing FBI investigation.” The petition does not provide any information about the FBI investigation. It does not indicate who is/are the subjects of the investigation. It does not state that Walter is a subject of, or somehow involved in, the investigation. Even assuming Cox is an FBI employee, it does not explain why the requested records—“records pertaining to sentencing and sentencing guidelines”—are necessary or have substantial relevance to a legitimate need of Cox (or the FBI). It does not “describe in detail the reasons the file is being sought and its relevance to the proceeding or other purpose for which petitioner wishes to inspect or obtain the file.” (Rule 5.552(a)(2).) We observe that section 827 authorizes a case file to be inspected without a court order by the “attorneys for the parties, judges, referees, other hearing officers, probation officers, and law enforcement officers who are actively participating in criminal or juvenile proceedings involving the minor.” (§ 827, subd. (a)(1)(E), italics added.) If Cox, as a law

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enforcement officer for the FBI, is actively participating in criminal or juvenile proceedings involving Walter, she would have been authorized to access the file without a court order and would not have needed to file a petition. (See § 827, subd. (a)(1)(E), (3)(A); rule 5.552(a).)

We acknowledge that the juvenile court did not grant access to Walter’s entire juvenile case file. Instead, it limited disclosure to the minutes of the June 5, 2025 disposition hearing. (See rule 5.552(c)(6) [court may permit access to the file “only insofar as is necessary”].) Still, this does not negate the conclusions that Cox did not demonstrate good cause nor show that the records are necessary and have substantial relevance to a legitimate need of Cox’s. (See ibid.) Therefore, the juvenile court abused its discretion in granting the petition.

DISPOSITION

The August 11, 2025 (filed August 14, 2025) order granting Cox’s petition for access to juvenile case file pursuant to section 827 is reversed. On remand, the juvenile court is directed to enter a new order denying the petition.

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_________________________

LANGHORNE WILSON, J.

WE CONCUR:

_________________________

HUMES, P. J.

_________________________

SMILEY, J.

In re Walter A.C. / A174048