In Navajo Express v. Superior Court (1986) 186 Cal. App. 3d 981 [231 Cal. Rptr. 165], a civil action for personal injuries by plaintiff seeking damages for brain damage and emotional distress, defendants sought plaintiff's juvenile court records, suggesting the records would show preexisting mental and emotional problems. The appellate court vacated the trial court's order denying the defendant's motion for disclosure of the juvenile court records because the plaintiff's condition was in issue, and the juvenile court should balance plaintiff's interests in confidentiality against defendant's interests. (See Parmett v. Superior Court (1989), 212 Cal. App. 3d 1261, 1269 [civil plaintiff sought unsealing of juvenile record of defendant's molestation of plaintiff; juvenile court in its discretion denied disclosure; held: civil trial court could not order disclosure, because civil plaintiff's interest was insufficient to entitle plaintiff, as a matter of constitutional right, to disclosure]; In re Keisha T. (1995) [balancing dependent wards' interests in confidentiality against interests of the press in exposing welfare agency's failure to protect children against abuse and neglect].)