Voice of San Diego v. San Diego Unified School Dist. CA4/1

CourtCalifornia Court of Appeal
DecidedMay 11, 2026
DocketD084327
StatusUnpublished

This text of Voice of San Diego v. San Diego Unified School Dist. CA4/1 (Voice of San Diego v. San Diego Unified School Dist. CA4/1) 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
Voice of San Diego v. San Diego Unified School Dist. CA4/1, (Cal. Ct. App. 2026).

Opinion

Filed 5/11/26 Voice of San Diego v. San Diego Unified School Dist. CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

VOICE OF SAN DIEGO et al., D084327

Plaintiffs and Appellants, (Super. Ct. No. 37-2018- 00026433-CU-WM-CTL) v.

SAN DIEGO UNIFIED SCHOOL DISTRICT,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of San Diego County, Keri G. Katz, Judge. Affirmed. Law Office of Felix Tinkov, Felix Tinkov; and Glen Smith for Plaintiffs and Appellants. John David Loy for First Amendment Coalition as Amicus Curiae on behalf of Plaintiffs and Appellants. Quarles & Brady, Jeffrey P. Michalowski and Jessika B. Russell for Defendant and Respondent. INTRODUCTION

The California Public Records Act (CPRA; Gov. Code,1 § 7920.000 et seq.) imposes a duty on an agency to determine whether a public records request seeks any disclosable records in its possession within 10 days from receipt of the request, or up to 24 days if there are “unusual circumstances.” (§ 7922.535, subd. (b); see id., subd. (a).) If there are disclosable records in the agency’s possession, the agency is then required to make the records “promptly available.” (§ 7922.530, subd. (a), italics added.) Contending that “promptly available” means “ ‘within days or a few weeks’ ” of the initial 10- or 24-day deadline, Voice of San Diego and its editor-in-chief Scott Lewis (sometimes together, Voice) alleged the San Diego Unified School District (District) routinely obstructs and delays the disclosure of public records. According to Voice, the District’s average time in producing records responsive to its CPRA requests submitted over a five-year period was 399 days. Voice filed a petition for writ of mandate asserting, among other causes of action, a taxpayer claim pursuant to Code of Civil Procedure section 526a to enjoin the District’s illegal expenditure of public funds to maintain the alleged unlawful CPRA practice. The trial court rejected Voice’s interpretation of the CPRA, and found the evidence did not prove the District engages in any unlawful practice of delaying or withholding public records. Because the court had previously adjudicated all other causes of action in favor of the District, it entered final judgment denying the petition for writ of mandate.

1 All further statutory references are to the Government Code unless otherwise stated.

2 We affirm. The CPRA does not precisely define the timeframe for the actual production of requested records, and we cannot graft a “within days or a few weeks” requirement onto section 7922.530, subdivision (a). Whether an agency has promptly produced records is to be determined case-by-case considering the scope and burden imposed on the particular agency by the particular request. We further conclude substantial evidence supports the trial court’s factual findings that the District did not maintain an unlawful practice of violating the CPRA. Because there is no basis for a taxpayer action where the challenged governmental conduct is legal, the trial court properly denied the petition for writ of mandate. BACKGROUND I. Overview of the CPRA and Taxpayer Action To provide context for the issues in this appeal, we begin with a brief overview of the CPRA and Code of Civil Procedure section 526a which authorizes taxpayer actions. A. The CPRA The California Legislature enacted the CPRA in 1968. (Stats. 1968, ch. 1473, § 39, p. 2945.) In doing so, the Legislature declared “access to information concerning the conduct of the people’s business is a fundamental

and necessary right of every person in this state.” (§ 7921.000;2

2 Effective January 1, 2023, the Legislature recodified the CPRA. (See § 7920.005; Stats. 2021, ch. 614, § 2.) The recodification renumbered the CPRA provisions but did not substantively change the law. (City of Gilroy v. Superior Court (2026) 19 Cal.5th 38, 47, fn. 2 (Gilroy), citing §§ 7920.100– 7920.120.) We will refer to the current section numbers throughout our opinion and cross reference the former section numbers where necessary.

3 Gilroy, supra, 19 Cal.5th at p. 51.) To advance this fundamental right, the CPRA provides that “every person has a right to inspect any public record, except as otherwise provided.” (§ 7922.525, subd. (a).) Unless the Legislature has expressly provided an exemption, “ ‘ “all public records are subject to disclosure.” ’ ” (Gilroy, at p. 51.) The CPRA’s right of access was enshrined in the state Constitution by the voters’ passage of Proposition 59 in 2004. The measure added Article I, section 3, subdivision (b)(1), which states: “The people have the right of access to information concerning the conduct of the people’s business, and, therefore, the meetings of public bodies and the writings of public officials and agencies shall be open to public scrutiny.” (Cal. Const., art. I, § 3, subd. (b)(1).) This right of access was implemented with the imperative that “[a] statute, court rule, or other authority . . . shall be broadly construed if it furthers the people’s right of access, and narrowly construed if it limits the right of access.” (Id., subd. (b)(2).) “The CPRA prescribes detailed procedures governing an agency’s response to a public records request.” (Gilroy, supra, 19 Cal.5th at p. 52.) It specifies two steps an agency must take in its response. First, the agency must determine whether the request for public records seeks any disclosable records in the agency’s possession within 10 days from receipt of the request, and then “promptly” notify the requester of its determination and its reasons for withholding any records. (§ 7922.535, subd. (a).) The agency is further required to “state the estimated date and time when the records will be made available” if it “determines that the request seeks disclosable public records.” (Ibid.) The 10-day deadline may be extended only in six specified “unusual circumstances” and, in any case, may not “result in an extension for more than 14 days,” for a total of 24 days. (Id., subds. (b), (c)(1)–(6).)

4 Second, the agency must produce the requested records. Here, section 7922.530, subdivision (a), provides that the agency “shall make the records promptly available to any person upon payment of fees covering direct costs of duplication, or a statutory fee if applicable.” (Italics added.) Section 7922.500 further provides, “Nothing in [the CPRA] shall be construed to permit an agency to delay or obstruct the inspection or copying of public records.” Our high court has observed that these CPRA provisions “impose a general duty on agencies to act promptly.” (Gilroy, supra, 19 Cal.5th at p. 52.) The CPRA authorizes any person seeking “to enforce that person’s right under [the CPRA] to inspect or receive a copy of any public record or class of public records” to bring an action for injunctive or declarative relief or a writ of mandate to obtain judicial review of an agency’s decision not to disclose requested records. (§ 7923.000.) If, after issuing an order to show cause, the court determines “the public official’s decision to refuse disclosure is not justified” under the CPRA, it “shall order the public official to make the record public.” (§§ 7923.110, 7923.100.) Thus, the remedy available under the CPRA is ordinarily a determination “whether a particular record or class

of records must be disclosed.”3 (County of Santa Clara v. Superior Court

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