FOIA precedents and the CPRA #2
Q: Would a Federal FOIA (Exemption 6) be precedent setting inCalifornia where the records in question fall under CPRA Section 6254(c) – personnel, medical, or similar files. Thank you. I appreciate it.CPRA exemption for private personal informationSection 6254Personnel, medical or similar files, the disclosure of which would constitute an unwarranted invasion of personal privacy.(b)(6) EXEMPTION 6 Personal Information Affecting an Individual’s Privacy. This exemption permits the government to withhold all information about individuals in “personnel and medical files and similar files” when the disclosure of such information would “constitute a clearly unwarranted invasion of personal privacy.” This exemption cannot be invoked to withhold from a requester information pertaining to the requester.
A: It appears that you are asking whether a federal court ruling interpreting a particular FOIA exemption is binding on California courts. Unfortunately, it is not. As was stated in an earlier response to your inquiry, California courts have noted that because the California Public Records Act (PRA) was modeled after the federal Freedom of Information Act (FOIA), judicial interpretation of the FOIA by federal courts may be used by California state courts when interpreting the PRA. See City of San Jose v. Superior Court, 74 Cal.App. 4th 1008, 1016 (Cal. Ct. App. 1999), quoting Times Mirror Co. v. Superior Court, 53 Cal. 3d 1325, 1338 (1991). However, federal court decisions — other than U.S. Supreme Court decisions — are not binding on state courts, and may only be used as helpful guidance.