In April 2023, California Highway Patrol (CHP) attempted to serve a search warrant on a man in a Roseville City Park. A shootout broke out between the man, CHP, and officers from the Roseville Police Department (the Department), who arrived after the shooting commenced. CHP officers, the man, and two hostages all had gunshot wounds.
A reporter from Sacramento Television Stations Inc. (Sac TV) made a California Public Records Act request that the Department release footage from the body worn cameras of the involved officers. The Department argued that its officers discharged fire arms only during a three-minute window of time. The Department released four 39-second clips body camera footage, some without sound, and audio clips of radio communications. A second Sac TV reporter responded, requesting the full footage from all body worn cameras and dash cameras at the scene of the incident. The Department maintained that it had released everything it was legally required to disclose, and asserted that it was only required to release footage of a narrow, critical incident, and not a larger criminal event.
Sac TV filed for a writ of mandate for access to all body worn camera footage from the time officers were dispatched to the scene to about one hour later. Although the superior court acknowledged that broad disclosure law required a recording of a shooting to include more than just the seconds before and after, the fact of City’s active investigation rendered it unnecessary for the court to determine precisely how much additional disclosure would have been required in this dispute. Accordingly, the superior court denied Sac TV’s mandate petition seeking an order compelling the City to disclose more recordings.
Sac TV then filed a petition for writ of mandate in the California Court of Appeal. The Court concluded that the superior court correctly determined that statute required more disclosure than the City provided. But, the Court found that the superior court’s “active investigation” finding was not supported by substantial evidence. Thus, the Court sent the case back to the superior court to conduct further proceedings, including an in camera review of the recordings, to determine the extent of additional disclosure required.
Sacramento Television Stations Inc. v. Superior Court of Placer County, 2025 Cal.App, LEXIS 406.