Petitioner, an individual, sought a writ of mandate to compel respondent, the Superior Court of San Diego County (California), to grant his request for an order requiring real party in interest, a community college district, to disclose under the California Public Records Act, Cal. Gov’t Code § 6250 et seq., the personal performance goals of its former superintendent.
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Overview
The trial court found that the goals were not incorporated into the employment contract, which would have mandated their disclosure as a matter of law under Cal. Gov’t Code § 6254.8. The trial court also found that the goals were exempt from disclosure under Cal. Gov’t Code § 6254(c) as personnel files. The court, in denying relief, concluded that although the employment contract referred to goal setting in conjunction with yearly performance evaluations, the goals were not terms of the contract. An employee’s personal performance goals were not ordinarily included in a public employment contract, and the reference to goal setting did not clearly and unequivocally evidence the parties’ intent to incorporate future goals into the contract, within the meaning of Cal. Civ. Code § 1642. Moreover, the exemption of Cal. Gov’t Code § 6254(c) for personnel files also applied to a public employee’s personal performance goals because they reflected highly personal details about employees. Disclosure of such goals would compromise substantial privacy interests. The goals were also part of the confidential evaluation process under Cal. Gov’t Code § 54957(b)(1).
Outcome
The court denied the petition.