In Sanborn v. Chronicle Pub. Co. (1976) 18 Cal.3d 406, the Court concluded that, although a decision by the clerk of a city and county to discuss a particular matter with the press may have been within the clerk's discretion (as that term is used in common parlance), it was not 'in the nature of a "basic policy decision" made at the "planning" stage of City's operations' but rather fell within the category of routine duties incident to the normal operations of the office of the clerk.