BILL ANALYSIS                                                                                                                                                                                                    






                             SENATE JUDICIARY COMMITTEE
                           Senator Ellen M. Corbett, Chair
                              2009-2010 Regular Session


          SB 982 (Hollingsworth)
          As Amended July 1, 2010
          Hearing Date: July 15, 2010
          Fiscal: Yes
          Urgency: Yes
          SK/BP:jd
                    

                                        SUBJECT
                                           
                 Deceased Child Victims' Protection and Privacy Act

                                      DESCRIPTION  

          This bill would enact the Deceased Child Victims' Protection and  
          Privacy Act, requiring, upon the request of a biological or  
          adoptive parent, spouse, or legal guardian of a deceased minor,  
          the sealing of the autopsy report and evidence associated with  
          the examination of that minor victim when the minor was a victim  
          of a crime that caused his or her death and a person has been  
          convicted and sentenced for committing that crime. This bill  
          would contain specified exceptions and would also provide that a  
          coroner or medical examiner shall not be liable for damages in a  
          civil action for any reasonable act or omission taken in good  
          faith compliance with the bill.

          (This analysis reflects author's amendments to be offered in  
          Committee.)

                                      BACKGROUND  

          The California Public Records Act (PRA) provides that all public  
          records of state and local agencies are open to public  
          inspection, unless exempt.  The PRA represents a balance between  
          the right of individuals to privacy and transparency and  
          openness in government, stating, "access to information  
          concerning the conduct of the people's business is a fundamental  
          and necessary right of every person in this state."  This right  
          was further underscored when voters approved Proposition 59 in  
          2004, which amended the California Constitution to provide that  
          the people have the right of access to information concerning  
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          the conduct of the people's business and, therefore, the  
          writings of public officials and agencies shall be open to  
          public scrutiny.  Under Proposition 59, a statute shall be  
          broadly construed if it furthers the people's right of access  
          and narrowly construed if it limits that right of access.   
          Coroner's reports have been deemed to be public records within  
          the meaning of the PRA and may be exempted from disclosure in  
          certain instances.  (Dixon v. Superior Court, 170 Cal.App.4th,  
          1271; Rev. denied, 2009 Cal. LEXIS 4729 (May 13, 2009).)
          This bill, which is sponsored by the San Diego District  
          Attorney's Office, was prompted by the recent tragic death of  
          Chelsea King in San Diego County.  The sponsor indicates that 22  
          PRA requests were made for Chelsea King's autopsy report.  While  
          the sponsor indicates that those PRA requests were denied under  
          existing provisions of the PRA which allow for nondisclosure of  
          investigative files, this bill would instead provide that  
          autopsy reports and associated evidence in the possession of a  
          public agency would, upon the request of certain family members,  
          be sealed and not disclosed in certain instances.

                                CHANGES TO EXISTING LAW
           
           1.Existing law  provides, under the PRA, that public records of  
            state and local agencies are open to inspection, unless  
            exempt.  (Gov. Code Sec. 6250 et seq.)  The PRA provides that  
            it shall not be construed to require disclosure of personnel,  
            medical, or similar files, "the disclosure of which would  
            constitute an unwarranted invasion or personal privacy."   
            (Gov. Code Sec. 6254(c).)  Records of investigations conducted  
            by any state or local police agency or investigatory files of  
            those agencies are also exempt from disclosure.  (Gov. Code  
            Sec. 6254(f).)

           Existing law  provides that public records may be exempt from  
            disclosure by express provisions of state or federal law.   
            (Gov. Code Sec. 6254(k).)  Existing law provides that an  
            agency shall justify withholding any record by demonstrating  
            that it is exempt from disclosure under express provisions of  
            law, as specified, or that on the facts of the particular case  
            the public interest served by not disclosing the record  
            clearly outweighs the public interest served by disclosure.   
            (Gov. Code Sec. 6255.)   

           Existing law  , the California Constitution, provides that the  
            people have the right of access to information concerning the  
            conduct of the people's business and, therefore, the writings  
                                                                      



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            of public officials and agencies shall be open to public  
            scrutiny.  The California Constitution also provides that a  
            statute shall be broadly construed if it furthers the people's  
            right of access and narrowly construed if it limits that right  
            of access.  (Cal. Const. Art. 1, Sec. 3.) 

           Existing law  , the California Constitution, provides that, among  
            other rights, all people have an inalienable right to pursue  
            and obtain privacy.  (Cal.  Const. Art. 1, Sec. 1.) 

           Existing law  , the California Constitution, provides that in  
            order to preserve and protect a victim's rights to justice and  
            due process, a victim shall be entitled to be treated with  
            fairness and respect for his or her privacy and dignity, and  
            to be free from intimidation, harassment, and abuse,  
            throughout the criminal or juvenile justice process.  (Cal.  
            Const. Art. 1, Sec. 28(b)(1).)

           Existing case law  provides that coroner and autopsy reports are  
            public records and may be exempt from disclosure under  
            Government Code Section 6254(f) when they "constitute  
            investigations of a suspected homicide death."  (Dixon v.  
            Superior Court, 170 Cal.App.4th 1271; Rev. denied, 2009 Cal.  
            LEXIS 4729 (May 13, 2009).)  

           Existing case law  provides that the intent of the PRA is to hold  
            government accountable while still protecting individual  
            privacy.  (Rackauckas v. Superior Court (2002) 104 Cal.App.4th  
            169; Cal. State Univ., Fresno Ass'n v. Superior Court (2001)  
            90 Cal.App.4th 810.)

           Existing law  prohibits any copy or reproduction to be made of  
            any photograph, negative, or print, including video  
            recordings, of the body, or any portion of the body, of a  
            deceased person, taken by or for the coroner at the scene of  
            death or in the course of a post mortem examination or  
            autopsy.  This prohibition does not apply to use in a criminal  
            action or proceeding that relates to the death of that person,  
            or except as a court permits, by order after good cause has  
            been shown and after written notification of the request for  
            the court order has been served to the district attorney, as  
            specified.  (Code Civ. Proc. Sec. 129.)

           This bill  would provide that, when a child under 18 years of age  
            is killed as a result of a criminal act and a person has been  
            convicted and sentenced for committing that act, the autopsy  
                                                                      



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            report and evidence associated with the examination of the  
            victim ("associated evidence") in the possession of a public  
            agency shall, upon the request of a qualifying family member  
            of the deceased child, be sealed and may not be disclosed. 

           This bill  would provide that an autopsy report and associated  
            evidence that has been sealed under the bill could be  
            disclosed to the following:

          a.   law enforcement, prosecutorial agencies and experts hired  
            by those agencies,   
               public social services agencies, or child death review  
               teams to be used solely for investigative, prosecutorial,  
               or review purposes and not disseminated further; 

             b.  the defendant and the defense team and experts hired by  
               the defense team in the course of criminal proceedings or  
               related habeas proceedings to be used solely for  
               investigative and review purposes and not disseminated  
               further; and    

            c.   civil litigants in a cause of action related to the  
            victim's death with a court order 
              upon a showing of good cause and proper notice to be used  
            solely to pursue the 
              cause of action and not disseminated further.

              This bill  would provide that a qualifying family member who  
            has been charged with or convicted of any act in furtherance  
            of the victim's death may not request that the autopsy report  
            and associated evidence be sealed under the bill.  Upon the  
            filing of charges against a qualifying family member, this  
            bill would specify that any seal maintained at the request of  
            that family member under the bill's provisions shall be  
            removed.

               This bill  would provide that if a qualifying family member  
            requests that an autopsy report and associated evidence be  
            sealed and another qualifying family member opposes that  
            sealing, the opposing party may request a hearing before the  
            superior court for a determination of whether the sealing  
            should be maintained.  This bill would provide for the  
            following in relation to such a hearing:

              a.   the opposing party must notify all other qualifying  
            family members, the medical 
                                                                      



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              examiner's office, and the district attorney's office at  
            least 10 court days in 
              advance of the hearing;

              b.   at the hearing, the court must consider: (1) the  
            interests of all qualifying family 
              members; (2) the protection of the memory of the deceased  
            child; (3) any 
              evidence that the qualifying family member requesting the  
            seal was involved in 
              the crime that resulted in the death of the child; (4) the  
            public interest in scrutiny 
              of the autopsy report or the performance of the medical  
            examiner; (5) any impact 
              that unsealing would have on pending investigations or  
            pending litigation; and 
              (6) any other relevant factors; 

              c.   official information in the possession of a public  
            agency necessary to the 
              determination of the hearing shall be received in camera  
            upon a proper showing;

              d.   in its discretion, the court may, to the extent  
            allowable by law and with good 
              cause shown, restrict the dissemination of an autopsy report  
            or evidence 
              associated with the examination of the victim;

              e.   the ability to oppose the sealing of the autopsy report  
            or unseal the autopsy 
              report under the bill shall not apply where a public agency  
            has independently 
              determined that the autopsy report may not be disclosed  
            pursuant to 
              Government Code Section 6254(f) because it is an  
            investigative file.  In that 
              instance, nothing in the bill shall preclude the application  
            of Government Code 
              Sections 6258 and 6259.
               
             This bill  would provide that a qualifying family member, or  
            biological or adoptive aunt, uncle, sibling, first cousin, or  
            grandparent of the deceased child may request that the seal be  
            removed.  That request must be adjudicated in the same manner  
            as provided for above when a qualifying family member opposes  
                                                                      



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            the initial sealing. 

             This bill  would provide that its provisions do not limit  
            public access to information contained in the death  
            certificate, including: name; age; gender; race; date, time,  
            and location of death; name of a physician reporting a death  
            in a hospital; name of the certifying pathologist; date of  
            certification; burial information; and cause of death. 

             This bill  would provide that when a medical examiner declines  
            a request to provide a copy of an autopsy report that has been  
            sealed pursuant to the bill's provisions, the examiner shall  
            cite the bill's provisions as the reason for the denial.
             This bill  would specify that nothing in the bill shall  
            prohibit the use of autopsy reports and evidence in relation  
            to court proceedings. 

             This bill  would provide that its provisions do not abrogate  
            the rights of victims, their authorized representatives, or  
            insurance carriers to request the release of information  
            pursuant to Government Code Section 6254(f) which permits  
            insurers to obtain information for claims purposes.
             
             This bill  would specify that a coroner or medical examiner  
            shall not be liable for damages in a civil action for any  
            reasonable act or omission taken in good faith compliance with  
            the bill.

             This bill  would contain the following definitions:

            a.  a "child who is under 18 years of age" does not include  
            any child who comes 
                 within either of the following descriptions: (1) he or  
              she is a dependent child of the juvenile court pursuant to  
              Welfare and Institutions Code Section 300 at the time of his  
              or her death; or (2) he or she was residing in a state or  
              county juvenile facility, or a private facility under  
              contract with the state or county for the placement of  
              juveniles, as a ward of the juvenile court pursuant to  
              Welfare and Institutions Code Section 602 at the time of his  
              or her death;

             b.  "evidence associated with the examination of the victim"  
              means any object, writing, diagram, recording, computer  
              file, photograph, video, DVD, CD, film, digital device, or  
              other item which was collected during or serves to document  
                                                                      



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              the   autopsy of a deceased child; and

            c.  "qualifying family member" means the biological or  
            adoptive parent, spouse, or   
              legal guardian.

             This bill  contains an urgency clause, stating that it is  
            necessary that the bill take effect immediately in order to  
            prevent, as soon as possible, autopsy information concerning  
            deceased children from being made available to the public.

             This bill  contains a severability clause and various  
            legislative findings and declarations.

           2.Existing law  governs criminal discovery.  (Pen. Code Sec. 1054  
            et seq.)

           This bill  would state that nothing in the bill shall limit the  
            discovery provisions set forth in Penal Code Section 1054 et  
            seq.

           3.Existing case law  provides for a First Amendment right of  
            access to court proceedings and court records.  (See, e.g.,  
            NBC Subsidiary (KNBC-TV) v. Superior Court (1999) 20 Cal. 4th  
            1178; In re Marriage of Burkle (2006) 135 Cal.App.4th 1045,  
            Rev. denied 2006 Cal. LEXIS 5955 (May 17, 2006).)  Existing  
            Rules of Court, based on that case law, provide that court  
            records are presumed to be open unless confidentiality is  
            required by law and specifies procedures for the sealing of  
            court records in trial and appellate courts.  (Cal. Rules of  
            Court, Rules 2.500, 2.550, 2.551, 8.46.) 

           This bill  would provide that nothing in the bill shall be  
            construed to limit the authority of the court to seal records  
            or restrict the dissemination of an autopsy report or evidence  
            associated with the examination of the victim under case law,  
            statutory law, or Rules of Court.  

                                        COMMENT
           
          1.  Stated need for the bill  
          
          The author writes:
          
            SB 982 will protect the privacy of the families of murder  
            victims by allowing them to request that autopsy reports not  
                                                                      



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            be subject to public records act requests.  This Act is  
            intended to limit the unnecessary dissemination of autopsy and  
            private medical information . . . [and] allow families to  
            request that the autopsy report of the victim be sealed from  
            public inspection.  This Act would not affect the  
            dissemination of the reports to law enforcement agents or  
            prosecutors [or defendants or civil litigants under] state and  
            federal discovery [laws].

            Currently there is no law which allows family members to  
            protect their privacy or the privacy of a loved one by  
            requesting that [autopsy reports] be sealed.  While an  
            investigative agency can decide not to disclose such  
            information, that decision is left to each individual agency.   
            Decisions by the agencies are frequently challenged in the  
            courts and through the media and other groups.  This law will  
            give the victim's family the right to seal the information  
            from unnecessary disclosure while still protecting the ability  
            to access such documents when legally necessary.

            Thousands of Californians are murdered each year, a statistic  
            that has remained steady for over 30 years.  The emotional  
            pain suffered by the families of these lost victims is  
            unimaginable.  That pain is relived through criminal  
            proceedings, which serve as a troubling reminder of the  
            suffering that loved ones endured before their lives were  
            taken.  No document is more telling of the specific nature of  
            a victim's injuries than the autopsy report crafted by a  
            Medical Examiner.   For the family of a crime victim, the  
            writing and diagrams contain the details of a loved one's last  
            experiences in this world.  While criminal proceedings and  
            certain civil actions may require the use of such documents to  
            satisfy the needs of a particular suit, there is no such  
            compelling interest in public production and distribution of  
            these documents. 



          2.  July 1, 2010 amendments  
          
          Prior to the July 1st amendments, this bill would have provided  
          that upon the request of a biological, adoptive, or foster  
          parent, spouse, or guardian of a deceased victim of  a crime who  
          was under 18 years of age, the autopsy report and evidence  
          associated with the examination of the victim shall be sealed  
          and not disclosed, except as specified.  
                                                                      



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          Opponents of the measure, in particular the Children's Advocacy  
          Institute (CAI), expressed several concerns about the bill  
          including that it might inadvertently permit an individual  
          responsible for the death of a child to request sealing of the  
          autopsy report and therefore hide his or her involvement in the  
          death.  CAI also argued that the bill was "predicated on the  
          belief" that there was never a compelling interest in public  
          disclosure and distribution of a murdered child's autopsy  
          report.  In particular, CAI raised concerns that there is a  
          compelling interest in disclosure when children die while in  
          foster care or juvenile custody situations.  Similarly, the  
          California Newspaper Publishers Association (CNPA) noted that  
          autopsy reports have been used in a number of articles exposing  
          abuse or wrongful behavior and cited the recent Sacramento Bee  
          investigative series reporting on the death of  
          four-and-a-half-year old Amariana Crenshaw which was based in  
          part on autopsy reports.  That series resulted in Sacramento  
          County's Child Protective Services admitting it had failed to  
          protect the little girl from harm when it did not sufficiently  
          investigate numerous allegations of abuse and neglect by the  
          girl's foster mother.

          In response to the concerns expressed by opponents, the bill was  
          amended to address the situation in which a child has been  
          murdered and the person responsible has been convicted and  
          sentenced for the crime.  The July 1st amendments exempt  
          instances where a child has died while in foster care or custody  
          of the juvenile justice system.  The amendments also provide a  
          court process when a qualifying family member requests sealing  
          and another qualifying family member objects to that sealing.   
          As amended on July 1, that same court process would apply when  
          specified family members seek to unseal the information.  Based  
          on these amendments, CAI has indicated that it is no longer  
          opposed to the bill.  CNPA, while still opposed to the measure,  
          notes that, in its view, the amendments recognize the important  
          public interest in disclosure of autopsy reports in the death of  
          a child.  

          3.  Bill would create exception to the Public Records Act;  
            application to autopsy reports in the possession of a public  
            agency  
          
          This bill would require, upon the request of a biological or  
          adoptive parent, spouse, or legal guardian of a deceased minor,  
          the sealing of the autopsy report and evidence associated with  
                                                                      



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          the examination of that minor victim in the possession of a  
          public agency when the minor was a victim of a crime that caused  
          his or her death and a person has been convicted and sentenced  
          for committing that crime.  The purpose of the bill, as noted in  
          the legislative findings and declarations and supported by  
          background materials provided to the Committee, is to allow  
          "families of deceased minor victims of violent crimes . . . to  
          request that autopsy reports not be subject to public records  
          act requests."  

          Under the PRA, public records of state and local agencies are  
          open to inspection, unless they are exempt.  For example, public  
          records may be exempt from disclosure when expressly provided  
          for under state or federal law.  This bill, by providing an  
          express exemption when a qualifying family member requests that  
          the autopsy report of a deceased minor in the possession of a  
          public agency be sealed in certain instances, creates such an  
          exception to the PRA.  In addition, this bill's restrictions  
          would apply only to the disclosure of autopsy reports and  
          associated evidence "in the possession of a public agency."  The  
          term "public agency" does not include the judiciary.  For  
          example, the PRA specifically excludes the judicial branch from  
          its definition of "public agency."  That lack of application to  
          court records is consistent with the sponsor's letter of support  
          for the bill stating that it would require "that Medical  
          Examiners/Coroners seal the autopsies of murdered children upon  
          the request of the parent."  The bill's use of the term "seal,"  
          a phrase not generally used in the PRA context, should not be  
          determinative here as the sponsor has indicated that when  
          coroners determine that an autopsy report is not subject to  
                                              disclosure under Government Code Section 6254(f) because it is  
          an investigative file, they "seal" the report.  

          While the plain language of the bill does not apply to autopsy  
          reports and associated evidence held by a court, the sponsor now  
          indicates that the intent of the drafter was to apply this  
          bill's restrictions on disclosure to autopsy reports and  
          associated evidence entered into the court record.  Should this  
          bill be amended to expressly apply to court records, important  
          constitutional and workability issues would arise as discussed  
          below. 

              a.   Potential constitutional concerns should the bill be  
               amended to specifically apply to court records

             Should this bill be amended to apply its restrictions on  
                                                                      



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            disclosure to court records, it would thus require that an  
            autopsy report and associated evidence entered into the court  
            record be sealed from public view upon the request of a  
            biological or adoptive parent, spouse, or legal guardian of a  
            deceased minor when the minor was a victim of a crime that  
            caused his or her death and a person has been convicted and  
            sentenced for committing that crime.  Absent appropriate  
            safeguards, such a mandatory sealing may not meet  
            constitutional muster.  Under existing law, the First  
            Amendment provides a right to public access of court records  
            and court proceedings and existing California Rules of Court  
            implement that right.  (See, e.g., NBC Subsidiary (KNBC-TV) v.  
            Superior Court (1999) 20 Cal.4th 1178; In re Marriage of  
            Burkle (2006) 135 Cal.App.4th 1045, Rev. denied 2006 Cal.  
            LEXIS 5955 (May 17, 2006); Cal. Rules of Court, Rules 2.500,  
            2.503, 2.550, 8.46.) 

            Under NBC Subsidiary and the California Rules of Court derived  
            from that case, a court must meet certain requirements before  
            it may close a hearing or seal a record.  Specifically, the  
            court must expressly find that: (1) there exists an overriding  
            interest that overcomes the right of public access to the  
            record; (2) the overriding interest supports sealing the  
            record; (3) a substantial probability exists that the  
            overriding interest will be prejudiced if the record is not  
            sealed; (4) the proposed sealing is narrowly tailored; and (5)  
            no less restrictive means exist to achieve the overriding  
            interest.  In Burkle, which implicated personal, not familial,  
            privacy, the court held that Family Code Section 2024.6 "is  
            unconstitutional on its face as an undue burden on the First  
            Amendment right of public access to court records." (Burkle,  
            supra, 135 Cal.App.4th at 1070.)   Section 2024.6 required a  
            court, upon the request of a party to a divorce proceeding, to  
            seal any pleading that lists the location or identifying  
            information about the parties' financial assets and  
            liabilities.  Under Section 2024.6, records sealed could be  
            unsealed upon petition to the court and good cause shown.  

            In finding Section 2024.6 to be unconstitutional, the Burkle  
            court noted in particular the mandatory sealing required by  
            the statute and determined that it did not conform to the  
            requirements of the First Amendment as set out by NBC  
            Subsidiary. Should this bill be amended to specifically apply  
            to court records, its mandatory sealing provisions as to court  
            records (combined with a much narrower unsealing provision and  
            different privacy interest) would arguably raise similar  
                                                                      



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            constitutional concerns.

            WOULD NOT THE APPLICATION OF THIS BILL TO COURT RECORDS  
            WITHOUT APPROPRIATE SAFEGUARDS VIOLATE THE FIRST AMENDMENT  
            RIGHT TO PUBLIC ACCESS TO COURT RECORDS?

              b.   Workability issues should the bill be amended to  
               specifically apply to court records

             Should this bill be amended to apply its restrictions to court  
            records, it would arguably raise workability issues as the  
            process for sealing the autopsy report and associated evidence  
            is not clear from the language of the bill.  For example,  
            would the qualifying family member make the request for  
            sealing to the court, or to the coroner, or the district  
            attorney's office?  In addition, because only certain  
            individuals are "qualifying family members," there would have  
            to be some determination that the individual requesting that  
            the record be sealed met the definition of "qualifying family  
            member."  And, some determination also must be made that a  
            person has been convicted and sentenced for the commission of  
            the criminal act that killed the minor and that the minor was  
            not either in foster care or in juvenile custody at the time  
            of his or her death.  If amended, there are likely additional  
            workability issues such as whether Judicial Council would be  
            required to create a form, change any Rules of Court, or  
            whether current practices and procedures regarding the sealing  
            of court records would need to be changed. 



          4.  Bill would permit specified persons to request unsealing  
          
          This bill would provide that a qualifying family member, aunt,  
          uncle, sibling, first cousin, or grandparent of the deceased  
          child may request that the seal be removed.  That request must  
          be adjudicated in the same manner as provided for when a  
          qualifying family member opposes the initial sealing.  Under the  
          bill, the individual requesting that the autopsy report and  
          associated evidence be unsealed must, at least 10 court days in  
          advance of the court hearing on the matter, notify all other  
          qualifying family members, the medical examiner's office, and  
          the district attorney's office.  

          At the hearing, the bill would require the court to consider all  
          of the following: (1) the interests of all qualifying family  
                                                                      



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          members; (2) the protection of the memory of the deceased child;  
          (3) any evidence that the qualifying family member requesting  
          the seal was involved in the crime that resulted in the death of  
          the child; (4) the public interest in scrutiny of the autopsy  
          report or the performance of the medical examiner; (5) any  
          impact that unsealing would have on pending investigations or  
          pending litigation; and (6) any other relevant factors.   
          Finally, should the court permit the unsealing, the bill would  
          provide that in its discretion, the court may, to the extent  
          allowable by law and with good cause shown, restrict the  
          dissemination of an autopsy report or evidence associated with  
          the examination of the victim.

          Opponent California Newspaper Publishers Association (CNPA)  
          writes that while permitting specified individuals to request  
          that the autopsy report and associated evidence be unsealed "is  
          absolutely necessary to protect the public from the unintended  
          consequences of allowing private individuals with private  
          agendas to make public record access decisions on behalf of the  
          state, it is, in its current form, nonetheless indefensible.  .  
          . .  persons besides qualifying family members could have  
          information that the qualifying family member who requested the  
          sealing was somehow involved in the crime."  CNPA continues with  
          the following scenario:

            A mother of a child for years ignores and takes active steps  
            to cover up the routine beating, molestation or mistreatment  
            of her child at the hands of her boyfriend, who is ultimately  
            convicted in connection with the child's death.  She does such  
            a good job of it, the situation never reaches the eyes and  
            ears of child protective services.  Immediately after  
            conviction, a plea deal-no public trial, she requests sealing  
            of the autopsy records as a means to protect herself from  
            further official scrutiny.  No qualifying family members exist  
            to object to the request.  Her best friend, though, or her  
            neighbor, or her employer, or an enterprising newspaper, have  
            identified substantial evidence that implicates the mother in  
            the child's death.  Under SB 982, none of these people would  
            be able to crack open the courtroom door, let alone make a  
            pitch for public disclosure in the interests of justice.  At a  
            minimum, SB 982 should be amended to allow access to the  
            courts to anyone with information about the crime to argue, on  
            the facts of the case, that the public interest in disclosure  
            clearly outweighs the public interest in nondisclosure.

          5.  Existing law already prohibits disclosure of coroner  
                                                                      



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            photographs  
          
          Existing law prohibits any copy or reproduction to be made of  
          any photograph, negative, or print, including video recordings,  
          of the body, or any portion of the body, of a deceased person,  
          taken by or for the coroner at the scene of death or in the  
          course of a post mortem examination or autopsy.  This  
          prohibition does not apply to use in a criminal action or  
          proceeding that relates to the death of that person, or except  
          as a court permits, by order after good cause has been shown and  
          after written notification of the request for the court order  
          has been served to the district attorney, as specified.  (Code  
          Civ. Proc. Sec. 129.)  This provision of law was added in order  
          to separate out photographs and other more "salacious"  
          information, thereby declaring copies of that information to be  
          protected from disclosure, from written reports.  

          This bill would also define "evidence" in a way that overlaps  
          with the provisions of existing law described above.   
          Specifically, in relevant part, the bill defines "evidence" to  
          mean any recording, photograph, or video which was collected  
          during or serves to document the autopsy of a deceased child.   
          Because it is not clear why these items of information are  
          included in this bill when they are already protected under  
          existing law, the Committee may wish to inquire of the author  
          and his sponsor the rationale for their inclusion.
           
          6.  Existing authority of court to seal autopsy reports not  
            impacted  
          
          This bill, as proposed to be amended, would specifically provide  
          that it may not be construed to limit the authority of the court  
          to seal records or restrict the dissemination of an autopsy  
          report or associated evidence under case law, other statutory  
          law, or Rules of Court.  This language is intended to make clear  
          that existing provisions of law which permit a party to a  
          proceeding to request that court records, such as autopsy  
          reports, be sealed are separate and distinct from the PRA  
          exemption created under this bill.  

          For example, under existing law, a defendant has a right to  
          request that an autopsy report be sealed.  Under this bill,  
          however, a qualifying family member who has been charged with or  
          convicted of the crime leading to the minor's death could not  
          request that the autopsy report be sealed pursuant to the  
          provisions of this bill.  The California Public Defenders  
                                                                      



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          Association (CPDA) raised concerns that the bill thus could lead  
          to "a defendant's motion being inappropriately denied or an  
          appropriately granted seal being lifted" when the request is  
          made pursuant to existing provisions of law.  The language added  
          by the proposed amendments would appear to address this concern.  


          7.  Position of California Public Defenders Association  
          
          CPDA has an "oppose unless amended" position on this bill but  
          indicates that, should the bill be amended as described in this  
          analysis, those amendments "would address our concerns  
          sufficiently to change our position to 'Neutral'."
           Support  :  California District Attorneys Association 

          Opposition  : California Broadcasters Association; California  
          Newspaper Publishers Association; California Public Defenders  
          Association (unless amended)

                                        HISTORY
           
           Source  :  San Diego County District Attorney, Bonnie Dumanis

           Related Pending Legislation  :  None Known

           Prior Legislation  :  AB 2521 (Nation, 2004) originally would have  
          restricted the release of autopsy reports under the PRA by  
          defining "medical files" under the PRA to include autopsy  
          reports.  In response to concerns, the bill was subsequently  
          amended to require coroners to notify a decedent's next of kin  
          when a PRA request has been made for the coroner's report on the  
          decedent.  This bill was set for hearing in this Committee, but  
          the author pulled the bill from the hearing calendar.

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