Question
Would a Federal FOIA (Exemption 6) be precedent setting in California 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 information Section 6254 Personnel, 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.
Answer
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.
Asked & Answered posts should not be relied on as legal advice, and FAC makes no guarantees about their completeness or accuracy. All posts carry a date of publication that readers should take note of in assessing their usefulness, given that laws and interpretations of them may change over time. Posts predating Jan. 1, 2023, that discuss the California Public Records Act may contain statute numbers no longer in use. Please see this page for a table showing how the California Public Records Act has been renumbered.