Estuardo Ardon, Plaintiff and Respondent v. City of Los Angeles, Defendant and Appellant

Summary

The court held that an agency’s inadvertent release of attorney-client privileged or attorney work product documents in response to a Public Records Act request does not waive the applicable exemption. It interpreted the statutory waiver provision in context, concluding that it addresses voluntary and knowing disclosures and prevents selective disclosure, not accidental releases. The court reversed the Court of Appeal and remanded for further proceedings concerning whether the release was truly inadvertent, whether any document was otherwise unprivileged or waived, and whether counsel should be disqualified.