Uribe v. Howie

In Uribe v. Howie (1971) 19 Cal.App.3d 194, a farmworker who had physical disorders she suspected were caused by crop pesticides sought permission to inspect monthly pesticide spray reports. The trial court found the reports exempt under Government Code section 6254, subdivision (f) as investigatory files compiled for correctional, law enforcement or licensing purposes. (Uribe v. Howie, supra, at p. 212.) The appellate court disagreed. While the spray reports may have been used in reviewing licenses, that was not the primary purpose for which they were compiled, nor were they currently being put to that use. (Id. at p. 213.)