White v. Superior Court

In White v. Superior Court (2002) 102 Cal.App.4th Supp. 1, the Inspector General claimed privilege over certain materials pursuant to a statute stating that the information was " 'deemed confidential for use by the Inspector General ... only.' " (Id. at p. Supp. 5.) The appellate court ruled that the statute did not establish an absolute privilege within the meaning of Evidence Code section 1040, stating that "information that is confidential is protected against unrestricted public inspection, but limited disclosure is not the equivalent of a privilege against any disclosure. ...... Although inspection of the Inspector General's records is restricted by statute, it is not forbidden ...." (White, at pp. Supp. 5-6.)