January 11, 2017 -- Client Alert
On December 29, 2016, the Supreme Court of California issued its decision in Los Angeles County Board of Supervisors v. Superior Court (ACLU of Southern California), Case No. S226645. The Court held invoices for legal services transmitted to a governmental agency by outside counsel are not categorically exempt from disclosure under California Public Records Act (“PRA”). However, the contents of a legal invoice are privileged to the extent they either communicate information for the purpose of legal consultation or risk exposing information that was communicated for such a purpose. The latter category includes protecting, in their entirety, invoices that reflect work in active and ongoing litigation matters.