State ex rel. Department of Transportation v. Superior Court

693 P.2d 804, 37 Cal. 3d 847, 210 Cal. Rptr. 219, 1985 Cal. LEXIS 239
CourtCalifornia Supreme Court
DecidedJanuary 31, 1985
DocketL.A. No. 31969
StatusPublished
Cited by9 cases

This text of 693 P.2d 804 (State ex rel. Department of Transportation v. Superior Court) is published on Counsel Stack Legal Research, covering California Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State ex rel. Department of Transportation v. Superior Court, 693 P.2d 804, 37 Cal. 3d 847, 210 Cal. Rptr. 219, 1985 Cal. LEXIS 239 (Cal. 1985).

Opinion

Opinion

BIRD, C. J.

Does an accused facing criminal charges arising out of an automobile collision have a “proper interest” under Vehicle Code section 20012 in discovering reports of other accidents at the same location?

[850]*850I.

Real party in interest, Phyllis Hall, was involved in an automobile accident in which her car collided with another car and five occupants were killed. Ms. Hall was charged with five counts of murder (Pen. Code, § 187), five counts of vehicular manslaughter (Pen. Code, § 192, subd. 3), and one count of drunk driving (Veh. Code, § 23152, subds. (a) and (b)).1

Following her arraignment, Ms. Hall served a subpoena duces tecum on the California Department of Transportation (Department) requesting production of accident reports of collisions which had occurred during the years 1980 through 1983 at the location of the incident. The Department refused to disclose the reports,2 asserting a privilege under sections 20012 and 20014.3 However, the trial court ruled that Ms. Hall had a “proper interest” in the reports under section 20012 and ordered their disclosure.

[851]*851The Department seeks review of this order, contending that it contravenes the confidentiality provisions of sections 20012 and 20014. Ms. Hall maintains that she is entitled to copies of the accident reports, since she is a person with a “proper interest” under section 20012. She states that at present she is willing to accept these reports with names and other identifying data deleted, subject to a later request for this information accompanied by a showing of particularized need.

If she is not granted this discovery, Ms. Hall contends that she is entitled to sanctions under Evidence Code section 1042, subdivision (a).4 The Los Angeles County District Attorney urges that Ms. Hall is entitled to discover the reports. Therefore, he argues, the question of sanctions does not arise. It is in this posture that this petition reaches this court.

II.

In Davies v. Superior Court (1984) 36 Cal.3d 291 [204 Cal.Rptr. 154, 682 P.2d 349], this court held that TASAS data,5 derived from accident reports, is not protected from discovery by the provisions of section 20012. In enacting that statute, Davies observed, “the Legislature intended to protect the privacy of the reporting parties by keeping confidential their identities and information that might disclose identity.” (Id., at p. 299.) There was no legislative intent to keep confidential “either the fact of the accident or information about its nature and causation.” (Ibid.) Accordingly, Davies adopted “[a] construction [of section 20012] which limits confidentiality of accident reports to the reports themselves and to identifying data . . . .” (Id., at p. 300.)

The party seeking discovery in Davies—a civil plaintiff who claimed injuries arising from an automobile accident—sought only TASAS data concerning other accidents at the same location. He sought neither the actual reports of these accidents nor the identifying data. Thus, a majority of this court did not address the question of whether one who is not a party to an accident may have a “proper interest” in the reports of it. (See id., at pp. 302-306 (conc. opn. of Bird, C. J.).)

[852]*852Here, Ms. Hall seeks discovery of those reports, although she agrees to the deletion of the names, addresses, or other information which could identify the reporting persons. Accordingly, this court must decide whether a person charged with a crime arising from an automobile accident may have a “proper interest” in reports of other accidents at the same location.

Davies involved a discovery request by a civil litigant. Here, the request arises in the context of a criminal prosecution. “Unlike the statutory development of civil discovery in California, the right of an accused to seek discovery in the course of preparing his defense to a criminal prosecution is a judicially created doctrine evolving in the absence of guiding legislation.” (Pitchess v. Superior Court (1974) 11 Cal.3d 531, 535 [113 Cal.Rptr. 897, 522 P.2d 305].) “Authority for such discovery derives not from statute but from the inherent power of every court to develop rules of procedure aimed at facilitating the administration of criminal justice and promoting the orderly ascertainment of the truth.” (Joe Z. v. Superior Court (1970) 3 Cal.3d 797, 801-802 [91 Cal.Rptr. 594, 478 P.2d 26].) “Allowing an accused the right to discover is based on the fundamental proposition that he is entitled to a fair trial and an intelligent defense in light of all relevant and reasonably accessible information.” (Pitchess, supra, 11 Cal.3d at p. 535.)

A ruling on an accused’s discovery request must reflect “our fundamental concern that an accused be provided with a maximum of information that may illumine his case. [Citation.]” (Ballard v. Superior Court (1966) 64 Cal.2d 159, 167 [49 Cal.Rptr. 302, 410 P.2d 838, 18 A.L.R.3d 1416].) Thus, an accused should be allowed to discover “ ‘any unprivileged evidence, or information that might lead to the discovery of evidence, if it appears reasonable that such knowledge will assist him in preparing his defense. . . .’” (Ballard, supra, 64 Cal.2d at p. 167, quoting Traynor, Ground Lost and Found in Criminal Discovery (1964) 39 N.Y.U. L.Rev. 228, 244, italics omitted.) “Absent some governmental requirement that information be kept confidential for the purposes of effective law enforcement, the state has no interest in denying the accused access to all evidence that can throw light on issues in the case . . . .” (People v. Riser (1956) 47 Cal.2d 566, 586 [305 P.2d 1].)

This court has held that the inherent judicial power to order discovery must be “tempered and restrained” when it potentially conflicts with existing legislation. (People v. Municipal Court (Runyan) (1978) 20 Cal.3d 523, 528 [143 Cal.Rptr. 609, 574 P.2d 425, 2 A.L.R.4th 681].) However, the legislative amendments to section 20012, and that statute’s judicial construction in Davies, demonstrate that section 20012 protects only a limited [853]*853privacy interest. That interest would not be impaired by affording discovery in this case.

As Davies found, section 20012 is intended to protect the identity of the reporting party from indiscriminate disclosure. (Davies, supra, 36 Cal.3d at p. 299.) The Legislature did not intend to preserve the confidentiality of any information about the accident other than the identity of the reporting person.

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Bluebook (online)
693 P.2d 804, 37 Cal. 3d 847, 210 Cal. Rptr. 219, 1985 Cal. LEXIS 239, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-department-of-transportation-v-superior-court-cal-1985.