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El Dorado Savings & Loan Assn. v. Superior Court
Citations: 190 Cal. App. 3d 342; 235 Cal. Rptr. 303; 1987 Cal. App. LEXIS 1507Docket: C000774
Court: California Court of Appeal; February 19, 1987; California; State Appellate Court
Petitioners El Dorado Savings and Kenneth T. Morris seek a prerogative writ to nullify a superior court order compelling the production of Morris's personnel file in a discrimination case brought by former employees of El Dorado, alleging gender and age discrimination. El Dorado refused to produce the file, citing Morris's right to privacy. The superior court ordered the file's production, prompting the petition. The court initially restrained enforcement of the order pending review and considered a peremptory writ. The ruling addresses two key issues: 1) The court finds that the general principle against reviewing discovery orders does not apply here due to the claim of privilege regarding Morris's personnel file. 2) Regarding standing, the court concludes that Morris did not waive his objection to the production despite not filing a separate opposition, as counsel for El Dorado represented both parties in the proceedings. The court emphasizes that Article I, section 1 of the California Constitution protects the right to privacy, a fundamental interest linked to various constitutional rights. The court's decision to issue a peremptory writ reflects the significant privacy concerns surrounding the compelled disclosure of Morris's personnel file. The constitutional right to privacy may be limited when a compelling public interest justifies such abridgment. One significant public interest is the state's aim to uncover the truth in legal proceedings, as reflected in California's discovery statutes. When privacy rights clash with the need for discovery, a careful balancing of these interests is required. In this case, while plaintiffs recognize that Morris's personnel records are protected, they argue that accessing these records is essential for their employment discrimination claims. They contend that Morris is uniquely situated compared to them, having received benefits they did not, and that his personnel file is necessary to challenge El Dorado's defense. However, the court emphasizes that even relevant confidential information cannot be disclosed without first balancing the necessity of discovery against privacy rights. If the balance favors disclosure, it must be done with strict limitations on scope. The court finds the record insufficient to justify the release of Morris's entire personnel file, suggesting that alternative, less intrusive methods, such as depositions, should be considered first. If no such alternatives exist, the court recommends an in-camera review to determine which specific parts of the file may be relevant to the case, rather than disclosing the entire file. Ultimately, the court intends to issue a peremptory writ of mandate to reverse the order compelling the production of Morris's entire personnel file and to require further proceedings consistent with these principles. The stay previously issued will be lifted once this decision becomes final. Judges Blease and Sparks concurred with this opinion.