Significant Public Interest in Investigation, Discipline of School Teacher Outweighs His Right to Privacy

Though personnel files are typically afforded protection from inquiring minds, the rules are a little bit different when there’s a significant public interest at issue. That was precisely the case in this recent decision by the California Court of Appeals.

A high school math teacher was subject to an investigation after allegations of sexual harassment were made against him by a student. The teacher was on administrative leave for two months, was reprimanded based upon the findings of the investigation, and returned to the classroom thereafter. Two years later, pursuant to the California Public Records Act, a parent requested disclosure of the documents relating to the investigation into the teacher’s conduct. The School notified he teacher that it would be releasing the investigation report and letter of reprimand, and the teacher objected on the grounds that such disclosure would violate his constitutional and statutory rights of privacy.

The trial court initially issued a temporary restraining order as to the disclosure, but ultimately denied the teacher’s request for a preliminary injunction to prevent the disclosure. The teacher appealed.

The Court of Appeals agreed with the trial court, and found that disclosure could be made pursuant to the California Public Records Act. Specifically, the Court recognized that while the teacher had a legally protected privacy interest in his personnel file documents, the potential harm to his privacy interests from disclosure did not outweigh the significant public interest in disclosure.