Spiers v. City and County of San Francisco
- Jacquelyn Corley
- 3:20-cv-01357
- U.S. District Court · Northern District of California
- 2
In Spiers v. City and County of San Francisco, Judge Corley granted plaintiffs’ video request but denied their sanctions request.
Dacari Spiers and Breonna Richard, who obtained removal of the confidentiality designation from the police body-camera video; the City and County of San Francisco, whose confidentiality designation was removed and whose opposing counsel was not sanctioned.
What happened
In Spiers v. City and County of San Francisco, plaintiffs Dacari Spiers and Breonna Richard asked the court to remove a confidential label from police body-camera video.
The court found that the City and County of San Francisco had not shown a specific harm that justified keeping the video confidential. The court also noted that the Police Department had already released part of the video.
Judge Corley granted the motion to remove the confidentiality designation but denied the plaintiffs’ request to sanction opposing counsel because that request was raised in a reply brief.
The detailed version
- Spiers v. City and County of San Francisco · No. 3:20-cv-01357
- Jacquelyn Corley
- Feb. 5, 2021
Background
Dacari Spiers and Breonna Richard challenged the City and County of San Francisco’s confidentiality designation for police body-worn-camera video. They also asked the court to sanction opposing counsel.
Confidentiality designation
The court granted the plaintiffs’ motion to remove the confidentiality designation. Under Federal Rule of Civil Procedure 26(c), the City had to show a particularized harm—a specific harm supporting confidential treatment—but the court found that it had not done so. The court considered the City’s position especially unpersuasive because the San Francisco Police Department had already released part of the body-camera video. The court also stated that, even if the City had shown a particularized harm, the relevant privacy factors would not favor confidentiality for the reasons discussed by another judge in a related decision.
Sanctions request and disposition
The court denied the plaintiffs’ motion to sanction opposing counsel because the request was raised in a reply brief. The order states that it disposes of Docket No. 38.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.