Judge: Mary H. Strobel, Case: 20STCP03274, Date: 2022-08-30 Tentative Ruling

Hon. Mary H. Strobel

The clerk for Department 82 may be reached at (213) 893-0530.


Case Number: 20STCP03274    Hearing Date: August 30, 2022    Dept: 82

Neil Chudgar,

v.

Department of Motor Vehicles, et al.

 

Judge Mary Strobel  

Hearing: August 30, 2022

 

20STCP03274

 

Tentative Decision on Motion to Seal Court File

 

 

            Petitioner Neil Chudgar (“Petitioner”) moves for an order sealing the court file pursuant to Penal Code section 851.91, and 851.92, as well as California Rules of Court 2.551 et seq.  Respondent Department of Motor Vehicles (“Respondent” or “DMV”) has stipulated to, and did not file an opposition to the motion to seal the entire court file in this action. 

 

Relevant Procedural History

 

            On October 9, 2020, Petitioner filed a verified petition for writ of mandate, which challenged Respondent’s suspension of Petitioner’s driver’s license for one year.  The suspension arose from Petitioner’s failure to take a chemical test when arrested for suspicion of DUI.  Also on October 9, 2020, the court granted Petitioner’s ex parte application for a stay of the administrative order.

 

            On October 12, 2021, after considering the petition, the administrative record, body camera footage for the arrest at issue, briefing from Respondent, and oral arguments, the court granted the petition.  The court issued a written ruling, in which it found that Petitioner had not been given proper admonishment under the Vehicle Code of the consequences of refusal to take a chemical test.

 

            On October 26, 2021, the court entered judgment granting the writ of mandate.  The court issued a writ directing Respondent to set aside its September 28, 2020, order suspending the driving privileges of the Petitioner.

 

            On January 12, 2022, in Los Angeles Superior Court case number LAX21253, the Honorable Elizabeth Munisoglu granted Petitioner’s petition to seal arrest and related records pursuant to Penal Code sections 851.91 and 851.92. 

 

            On February 18, 2022, Petitioner and Respondent filed a proposed stipulation to seal the entire court file in the instant action, LASC case number 20STCP03274, “[i]n accordance with Judge Munisoglu's Court Order issued on January 12, 2022, and Penal Code section 851.91.” 

 

            On February 23, 2022, the court issued a minute order stating: “The court does not sign the stipulation.  The parties can file an application to seal with the showing required by California Rules of Court Rule 2.551 et seq. A sealing order in the criminal case does not retroactively act to seal the documents in the civil case which are already in the public record.”

 

            On June 8, 2022, Petitioner filed this motion to seal.  Respondent has not filed an opposition. 

 

Notice

 

Petitioner’s proof of service for the motion, filed June 8, 2022, states that Petitioner served the motion on Respondent by mail and email on February 5, 2022.  The proof of service was signed by Petitioner’s counsel on May 23, 2022.  The motion was signed by Petitioner’s counsel on June 8, 2022.  The court has not received an opposition to the motion.

 

The proof of service purports to show service on February 5, 2022, before the parties’ February 18 stipulation and the court’s February 23 minute order.  Also, the proof of service was purportedly signed before Petitioner’s counsel signed the motion.   Petitioner’s counsel should explain the discrepancies in dates in the proof of service and confirm whether the motion was timely served.  If Petitioner shows proper and timely service, the following analysis applies.   

 

Analysis

 

[S]ubstantive courtroom proceedings in ordinary civil cases are ‘presumptively open.’”  (NBC Subsidiary (KNBC-TV), Inc. v. Sup.Ct. (1999) 20 Cal.4th 1178, 1217.)  To allow sealing of the record, including redactions thereof, the court must make the necessary findings under California Rules of Court, Rules 2.550 and 2.551. 

 

California Rules of Court, Rule 2.550(d) provides that a court may order a record to be filed under seal only if it expressly finds facts that establish: (1) There exists an overriding interest that overcomes the right of public access to the record; (2) The overriding interest supports sealing the record; (3) A substantial probability exists that the overriding interest will be prejudiced if the record is not sealed; (4) The proposed sealing is narrowly tailored; and (5) No less restrictive means exist to achieve the overriding interest.  (CRC Rule 2.550(d).)  Significantly, “[t]he Court must not permit a record to be filed under seal based solely on the agreement or stipulation of the parties.”  (CRC Rule 2.551(a).)  Also significant, the sealing rules in Rule 2.550 et seq. “do not apply to records that are required to be kept confidential by law.”  (CRC Rule 2.550(a)(2).)

 

Petitioner argues that sealing of the entire court file is required by Penal Code sections 851.91 or 851.92 and Judge Munisoglu's January 12, 2022, order.  Petitioner contends that the sealing rules in Rule 2.550 et seq. do not apply because the court records “are required to be kept confidential by law.”  Alternatively, Petitioner argues that the requirements of section 2.550(d) to seal the court file are met. 

 

Penal Code Sections 851.91 or 851.92

 

Because they are important to the court’s ruling on the motion, the court sets forth relevant provisions of Penal Code sections 851.91 or 851.92 at length. 

 

Section 851.91 states, in pertinent part:

 

(a) A person who has suffered an arrest that did not result in a conviction may petition the court to have his or her arrest and related records sealed, as described in Section 851.92.

(1) For purposes of this section, an arrest did not result in a conviction if any of the following are true:

(A) The statute of limitations has run on every offense upon which the arrest was based and the prosecuting attorney of the city or county that would have had jurisdiction over the offense or offenses upon which the arrest was based has not filed an accusatory pleading based on the arrest.

(B) The prosecuting attorney filed an accusatory pleading based on the arrest, but, with respect to all charges, one or more of the following has occurred:

(i) No conviction occurred, the charge has been dismissed, and the charge may not be refiled.

(ii) No conviction occurred and the arrestee has been acquitted of the charges.

(iii) A conviction occurred, but has been vacated or reversed on appeal, all appellate remedies have been exhausted, and the charge may not be refiled.

 

….[¶]

 

(c) A petition to seal an arrest record pursuant to this section may be granted as a matter of right or in the interests of justice.

(1) A petitioner who is eligible for relief under subdivision (a) is entitled to have his or her arrest sealed as a matter of right unless he or she is subject to paragraph (2) [paragraph (2) is not applicable here] ….

 

[¶]

 

(e) If the court grants a petition pursuant to this section, the court shall do all of the following:

(1) Furnish a disposition report to the Department of Justice, pursuant to Section 13151, stating that relief was granted under this section.

(2)(A) Issue a written ruling and order to the petitioner, the prosecuting attorney, and to the law enforcement agency that made the arrest that states all of the following:

(B) The record of arrest has been sealed as to petitioner, the arrest is deemed not to have occurred, the petitioner may answer any question relating to the sealed arrest accordingly, and the petitioner is released from all penalties and disabilities resulting from the arrest, except as provided in Section 851.92 and as follows:

(i) The sealed arrest may be pleaded and proved in any subsequent prosecution of the petitioner for any other offense, and shall have the same effect as if it had not been sealed.

(ii) The sealing of an arrest pursuant to this section does not relieve the petitioner of the obligation to disclose the arrest, if otherwise required by law, in response to any direct question contained in a questionnaire or application for public office, for employment as a peace officer, for licensure by any state or local agency, or for contracting with the California State Lottery Commission.

(iii) The sealing of an arrest pursuant to this section does not affect petitioner's authorization to own, possess, or have in his or her custody or control any firearm, or his or her susceptibility to conviction under Chapter 2 (commencing with Section 29800) of Division 9 of Title 4 of Part 6, if the arrest would otherwise affect this authorization or susceptibility.

(iv) The sealing of an arrest pursuant to this section does not affect any prohibition from holding public office that would otherwise apply under law as a result of the arrest.

 

Section 851.92 states, in pertinent part:

 

(a) This section applies when an arrest record is sealed pursuant to Sections 851.87851.90851.911000.4, and 1001.9.

(b) When the court issues an order to seal an arrest, the sealing shall be accomplished as follows:

(1) The court shall provide copies of the order and a report on the disposition of the arrest, as follows:

(A) Upon issuing the order, the court shall provide a copy to the person whose arrest was sealed and to the prosecuting attorney.

(B) Within 30 days of issuing the order, the court shall forward a copy of the order to the law enforcement agency that made the arrest, to any other law enforcement agency that participated in the arrest, and to the law enforcement agency that administers the master local summary criminal history information that contains the arrest record for the sealed arrest.

….[¶]

 

(2) The arrest record shall be updated, as follows:

(A) The local summary criminal history information shall include, directly next to or below the entry or entries regarding the sealed arrest, a note stating “arrest sealed” and providing the date that the court issued the order, and the section pursuant to which the arrest was sealed. This note shall be included in all master copies of the arrest record, digital or otherwise.

(B) The state summary criminal history information shall include, directly next to or below the entry or entries regarding the sealed arrest, a note stating “arrest relief granted,” providing the date that the court issued the order and the section of the Penal Code pursuant to which the relief was granted. This note shall be included in all master copies of the arrest record, digital or otherwise.

(3) A police investigative report related to the sealed arrest shall, only as to the person whose arrest was sealed, be stamped “ARREST SEALED: DO NOT RELEASE OUTSIDE THE CRIMINAL JUSTICE SECTOR,” and shall note next to the stamp the date the arrest was sealed and the section pursuant to which the arrest was sealed. The responsible local law enforcement agency shall ensure that this note is included in all master copies, digital or otherwise, of the police investigative report related to the arrest that was sealed.

(4) Court records related to the sealed arrest shall, only as to the person whose arrest was sealed, be stamped “ARREST SEALED: DO NOT RELEASE OUTSIDE OF THE CRIMINAL JUSTICE SECTOR,” and shall note next to the stamp the date of the sealing and the section pursuant to which the arrest was sealed. This stamp and note shall be included on all master court dockets, digital or otherwise, relating to the arrest.

(5) Arrest records, police investigative reports, and court records that are sealed under this section shall not be disclosed to any person or entity except the person whose arrest was sealed or a criminal justice agency. Nothing shall prohibit disclosure of information between criminal history providers.

(6) Notwithstanding the sealing of an arrest, a criminal justice agency may continue, in the regular course of its duties, to access, furnish to other criminal justice agencies, and use, including, but not limited to, by discussing in open court and in unsealed court filings, sealed arrests, sealed arrest records, sealed police investigative reports, sealed court records, and information relating to sealed arrests, to the same extent that would have been permitted for a criminal justice agency if the arrest had not been sealed.

(c) Unless specifically authorized by this section, a person or entity, other than a criminal justice agency or the person whose arrest was sealed, who disseminates information relating to a sealed arrest is subject to a civil penalty of not less than five hundred dollars ($500) and not more than two thousand five hundred dollars ($2,500) per violation. The civil penalty may be enforced by a city attorney, district attorney, or the Attorney General. This subdivision does not limit any existing private right of action. A civil penalty imposed under this section shall be cumulative to civil remedies or penalties imposed under any other law.

(d) As used in this section and Sections 851.87851.90851.911000.4, and 1001.9, all of the following terms have the following meanings:

 

(1) “Arrest record” and “record pertaining to an arrest” mean information about the arrest or detention that is contained in either of the following:

(A) The master, or a copy of the master, local summary criminal history information, as defined in subdivision (a) of Section 13300.

(B) The master, or a copy of the master, state summary criminal history information as defined in subparagraph (A) of paragraph (2) of subdivision (a) of Section 11105.


(2) “Court records” means records, files, and materials created, compiled, or maintained by or for the court in relation to court proceedings, and includes, but is not limited to, indexes, registers of actions, court minutes, court orders, court filings, court exhibits, court progress and status reports, court history summaries, copies of state summary criminal history information and local summary criminal history information, and any other criminal history information contained in any of those materials.

 

Application of the Sealing Order to Court Records in this Writ Action 

 

            Petitioner contends that sealing of the court file in this writ action is required by the terms of Judge Munisoglu's January 12, 2022, order.  (Mot. 6-7.)   Judge Munisoglu's sealing order states that “the record of arrest in the following matter shall be sealed under the provisions of section 851.91 and the arrest deemed not to have occurred: Law enforcement agency report number: DR# 20 08 07329.”  This law enforcement agency report refers to an arrest report submitted with Petitioner’s ex parte application for a stay in this action and also with the administrative record.  (Ex Parte filed 10/9/10 at Exh. C.) 

 

The order contains a line “Court case number:” in which Judge Munisoglu or the requesting party could have entered the case number of the civil case.  The line in the order was left blank.  The order provides various statements about the effect of the sealing, but none of those statements referred to this writ action or court records in other proceedings. 

 

Judge Munisoglu's sealing order did not expressly require the sealing of any records in this separate civil case.  However, as discussed below, Petitioner argues the sealing order had the effect, by operation of sections 851.91 and 851.92, of requiring a sealing of the court file related to Petitioner’s writ of administrative mandamus.

 

 

Application of Penal Code Sections 851.91 and 851.92 to the Court Records in the Writ Action

 

            Petitioner contends that sections 851.91 or 851.92 are worded broadly and a sealing order granted under these statutes applies to “all court proceedings involving the arrest,” including civil proceedings in which the arrest records are already part of the public court file or the sealed arrest is discussed in a court’s statement of decision.  (Mot. 7-10.)  Petitioner raises a question of statutory interpretation. 

 

“The rules governing statutory construction are well settled. We begin with the fundamental premise that the objective of statutory interpretation is to ascertain and effectuate legislative intent. [Citations.] To determine legislative intent, we turn first to the words of the statute, giving them their usual and ordinary meaning. [Citations.] When the language of a statute is clear, we need go no further. However, when the language is susceptible of more than one reasonable interpretation, we look to a variety of extrinsic aids, including the ostensible objects to be achieved, the evils to be remedied, the legislative history, public policy, contemporaneous administrative construction, and the statutory scheme of which the statute is a part.”  (Nolan v. City of Anaheim (2004) 33 Cal.4th 335, 340.) 

 

When interpreting a statute, the court must construe the statute, if possible to achieve harmony among its parts.  (People v. Hull (1991) 1 Cal. 4th 266, 272.)   “When interpreting statutory language, we may neither insert language which has been omitted nor ignore language which has been inserted.”  (See People v. National Auto. and Cas. Ins. Co. (2002) 98 Cal.App.4th 277, 282.)  “[I]nterpretations which render any part of a statute superfluous are to be avoided.”  (Young v. McCoy (2007) 147 Cal.App.4th 1078, 1083.)  The court “must select the construction that comports most closely with the apparent intent of the Legislature, with a view to promoting rather than defeating the general purpose of the statute, and avoid an interpretation that would lead to absurd consequences.”  (People v. Jenkins (1995) 10 Cal.4th 234, 246.) 

 

Penal Code section 851.91(a) states that “[a] person who has suffered an arrest that did not result in a conviction may petition the court to have his or her arrest and related records sealed.”  Section 851.91(a)(1)(B) states that circumstances in which an arrest does not “result in a conviction” include when the prosecuting attorney filed an accusatory pleading based on the arrest but “no conviction occurred” or a conviction occurred “but has been vacated or reversed on appeal.”  As Petitioner points out, section 851.91(a)(1)(B) shows that a sealing order could apply “retroactively” to court files already in the public record.  (Mot. 9.)  However, the “accusatory pleading” and any subsequent appeal would only be filed in a court with “criminal jurisdiction.”  (See also § 851.91(b)(1)(B).)  Thus, section 851.91(a)(1)(B), standing alone, does not show legislative intent for the sealing order to apply to arrest records or statements about a sealed arrest that are already part of the public record in civil proceedings. 

 

Petitioner also cites to sealing rules in section 851.92 as evidence that the legislature intended the sealing order to apply to arrest-related records already part of the public record in pending civil proceedings.  (Mot. 7-10.) 

 

Section 851.92(b) specifies how the sealing “shall be accomplished” when a court issues an order to seal an arrest under section 851.91.  Section 851.92(b) states, inter alia, that the sealing shall be accomplished by the following actions related to “court records”:

 

(4) Court records related to the sealed arrest shall, only as to the person whose arrest was sealed, be stamped “ARREST SEALED: DO NOT RELEASE OUTSIDE OF THE CRIMINAL JUSTICE SECTOR,” and shall note next to the stamp the date of the sealing and the section pursuant to which the arrest was sealed. This stamp and note shall be included on all master court dockets, digital or otherwise, relating to the arrest.

 

(5) Arrest records, police investigative reports, and court records that are sealed under this section shall not be disclosed to any person or entity except the person whose arrest was sealed or a criminal justice agency. Nothing shall prohibit disclosure of information between criminal history providers.

 

Section 851.92(d)(2) defines “court records” to include: “records, files, and materials created, compiled, or maintained by or for the court in relation to court proceedings, and includes, but is not limited to, indexes, registers of actions, court minutes, court orders, court filings, court exhibits, court progress and status reports, court history summaries, copies of state summary criminal history information and local summary criminal history information, and any other criminal history information contained in any of those materials.” 

Petitioner argues section 851.92(b) requires sealing of any court records “related to the sealed arrest,”  and that “court records” is defined broadly and includes no express limitation to the records in criminal proceedings or the case in which the sealing order is made.  However, the section immediately preceding the definition of “court records” defines “arrest record” and “record pertaining to an arrest” to mean information about an arrest or detention that is contained in the local summary criminal history information, or state summary criminal history information.   Id.  There is some implication that court records would similarly be those related to criminal proceedings.  Section 851.92(b)(5) states that “court records that are sealed under this section shall not be disclosed to any person or entity except the person whose arrest was sealed or a criminal justice agency.”  The statute defines “criminal justice agency” to mean any agency of government that performs, as its principal function, activities related to the “apprehension, prosecution defense, adjudication, incarceration or correction of criminal suspects and criminal offenders.”  It includes a court of this state.  851.92(d)(4).  Again these sections imply that sealing is intended to apply to criminal proceedings. 

 

Petitioner argues an interpretation of the statutory scheme to apply only to criminal court proceedings would weaken the effectiveness of sections 851.91 and 851.92.  A person or entity that wished to locate sealed arrest records could do so by reviewing the public record in pending civil cases in which the sealed arrest report and related documents are included.  On the other hand, an interpretation of these provisions to require sealing, and prohibit dissemination of information regarding an arrest in separate administrative proceedings would also produce anomalous results.

 

As a threshold matter, an administrative challenge to a driver’s license suspension based on failure to take a required chemical test under the implied consent law is separate and apart from any criminal proceeding related to a DUI arrest.  Under the implied consent law in the Vehicle Code, consent to taking a chemical test when arrested for DUI is a condition of holding a driver’s license.  A suspension for failure to take the required test is lawful whether or not the license holder is charged with a DUI, and whether or not the holder is convicted of driving under the influence.   See, e.g., Burnstine v. Dep't of Motor Vehicles, (1996) 51 Cal. App. 4th 1428, 1431-1432 (“But, under the implied consent law, it has long been held that a refusal to take a chemical test does not require an intentional (or even purposeful) refusal; it occurs, quite simply, when the driver does not take one of the chemical tests. (citations omitted) Under those circumstances, the Legislature made the policy decision that a person acquitted of the criminal charge of willful refusal to take a chemical test may still have his or her license suspended administratively”.

            Pursuant to statute, the effect of a sealing order is that “[t]he record of arrest has been sealed as to petitioner, the arrest is deemed not to have occurred, the petitioner may answer any question relating to the sealed arrest accordingly, and the petitioner is released from all penalties and disabilities resulting from the arrest.”  (§ 851.91(e)(2)(B).)  However, section 851.91 also provides “the sealing of an arrest pursuant to this section does not relieve the petitioner of the obligation to disclose the arrest, if otherwise required by law, in response to any direct question contained in a questionnaire or application for public office, for employment as a peace officer, for licensure by any state or local agency, or for contracting with the California State Lottery Commission.  851.92(e)(2)(B)(ii).  The statute itself seems to recognize that different rules may apply when considering arrests in the context of state licensing procedures.

 

The court finds ambiguity in the statutory scheme as applied to a civil administrative challenge to a driver’s license suspension based on failure to take a chemical test.  Section 851.92(b)(4) and (5) state that court records related to the arrest must be sealed, but the statutes are unclear how that mandate is to be communicated to or executed by a civil court in which a separate administrative decision is challenged  when the arrest report is part of the public file, having been put in issue by the Petitioner.  The court notes that the administrative record containing the police report is lodged with the court, but not filed.  Here, however, Petitioner made the police report part of the public file when it attached the report to his request for a stay.

 

The sealing standard also provides limited guidance on how the civil court would determine whether court records in a pending civil administrative writ are sufficiently “related” to the sealed arrest such that they must be sealed.   For example, it would be noteworthy if section 851.91 were interpreted to require sealing of portion of the court’s statement of decision in a civil writ proceeding if it references the arrest report. 

 

Petitioner has not cited any legislative history to resolve these ambiguities in sections 851.91 and 851.92 as applied to the circumstances of this case.  The Respondent has not filed an opposition, or notice of non-opposition, stating DMV’s position on how Penal Code sections 891.91 and 851.92 sealing requirements apply to administrative writs challenging a driver’s license suspension for refusing to take a chemical test.  This is a question likely to recur.  The court will continue the hearing on the sealing request and direct the attorney general’s office to file a brief regarding its position.

 

Furthermore, Petitioner does not seek to seal some records in this writ action, but the entire court file.  On this record and briefing, the court is not persuaded that sections 851.91 and 851.92 make all records in this civil action “confidential” such that the sealing rules in CRC Rule 2.550(d) do not apply at all. 

 

            Counsel should further address these issues at the hearing, including any relevant legislative history. 

               

Sealing Parts of the Court File Related to His Arrest Pursuant to CRC Rule 2.550(d)

 

           

            As discussed above, the arrest report sealed by Judge Munisoglu's sealing order was submitted by Petitioner with his ex parte application for a stay and was part of the administrative record lodged with, but not maintained by the court.  (See Ex Parte filed 10/9/10 at Exh. C.)  The contents of the arrest report were discussed in the petition, Petitioner’s ex parte application for a stay, Respondent’s answer, Respondent’s writ brief, and the court’s ruling on the writ petition.  The arrest was documented visually and audibly in the body camera footage of the responding officers, as discussed and quoted in the court’s ruling on the writ petition. 

 

At least with respect to the police report itself, attached to Petitioner’s ex parte application for a stay, the court finds that (1) There exists an overriding interest that overcomes the right of public access to the record; (2) The overriding interest supports sealing of such records; (3) A substantial probability exists that the overriding interest will be prejudiced if the record is not sealed; (4) The proposed sealing of the arrest report is narrowly tailored; and (5) No less restrictive means exist to achieve the overriding interest.  (CRC Rule 2.550(d).) 

 

            However, Petitioner has not provided a complete discussion in his motion of what other court records in this writ action are “related to the sealed arrest.  Some court records substantively discuss the arrest or quote from the arrest report, the body cam footage, or other similar documents.  Other court records, including certain minute orders on procedural matters, the judgment, and the writ of mandate, do not expressly discuss the arrest.  Petitioner has not proposed a “narrowly sealed” order which would seal only those portions of the court file for which findings under Rule of court 2.550 could be made.

 

Conclusion

 

Subject to oral argument on the issues outlined above, the motion is continued so that the attorney general’s office provides its position in writing, the parties further address statutory interpretation, including any relevant legislative history, and Petitioner proposes a narrowly sealed order under Rule of Court 2.550 as discussed above.