Haynie v. Superior Court

In Haynie v. Superior Court (2001) 26 Cal.4th 1061, the California Supreme Court rejected an attempt to further limit the investigation exemption. Haynie involved a CPRA request for citizen reports and police radio calls following a "routine" police stop of an African-American motorist based on mere suspicion of criminal conduct. (The neighbor's call that prompted the stop did not necessarily describe a crime, and no arrests were made, although the motorist was handcuffed and briefly detained.) (Id. at p. 1065.) The requester in Haynie argued that there was no danger of disclosing the identity of confidential informants, threatening the safety of police agents, victims, or witnesses, or revealing investigative techniques. Despite this, the Supreme Court applied the investigation exemption: "Limiting the section 6254(f) exemption only to records of investigations where the likelihood of enforcement has ripened into something concrete and definite would expose to the public the very sensitive investigative stages of determining whether a crime has been committed or who has committed it." (Id. at p. 1070.)