March 23, 2026
Court of Appeal of the State of California, Fifth Appellate District
The Rule of City of Fresno is that "great bodily injury" as used in Penal Code section 832.7(b)(1)(A)(ii) for California Public Records Act disclosure of law enforcement records means "a significant or substantial physical injury" as defined in Penal Code section 12022.7(f)(1), under circumstances where records relate to incidents involving use of force by police officers against persons.
5/11/26
Court of Appeal, Fourth Appellate District, Division One
The Rule of Voice of San Diego is that an agency's compliance with the CPRA's duty to make records "promptly available" under Government Code section 7922.530(a) must be determined case-by-case considering the scope and burden imposed on the particular agency by the particular request, under circumstances where the CPRA does not impose a fixed timeframe for actual production of requested records.