L.A. County Bd. Supervisors v. Super. Ct.

Summary

The court held that legal-service invoices sent by outside counsel to a public agency are not categorically protected by the attorney-client privilege under the Public Records Act. Although invoices generally are created for billing rather than legal consultation, all information in an invoice for pending and active litigation is privileged because disclosure may reveal litigation strategy, while information concerning completed matters must be evaluated for whether it exposes confidential legal consultation. The court reversed the Court of Appeal and remanded for proceedings consistent with these principles.