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Housing Auth. of the County of Fresno, Cal. v. Valverde
C96300004-9 (Central Valley Mun. Ct. Firebaugh, Cal., filed Apr. 3, 1996). ; Clearinghouse Number: 51156
Description
Public Housing Tenants Argue That Sole Basis for Eviction, Evidence from Son’s Juvenile Court Records, Is Inadmissible
Abstract
Defendant public housing tenants have filed their brief in limine
in this action by plaintiff public housing authority (PHA) to evict
them after two incidents involving law enforcement and their son.
PHA obtained the sole evidence to support tenants’ eviction
from their son’s juvenile court records, which are
confidential under state law. A superior court standing order
purported to allow, in limited circumstances, the release of
juvenile court records to PHAs, which were required to file a
declaration that the records would be used only for eviction
proceedings and that the incident prompting eviction occurred on
the premises. Tenants argue that PHA violated this standing order
because it did not file a declaration and because the incident
complained of occurred off the premises. Even if the records had
been obtained in conformity with the standing order, their release
was impermissible because the standing order violates the law.
Tenants assert that the California legislature has affirmed
"its belief that juvenile court record[s], in general, should
be confidential" and has narrowly tailored exceptions to that
rule. The California Supreme Court recognized in T.N.G. v. Superior
Court, 4 Cal. 3d 767 (1971), that juvenile records should not be
released without the juvenile court’s express approval.
Because the standing order purports to legitimize dissemination of
juvenile records to governmental landlords for purposes of
evictions, it provides less rights to a class of people (public
housing tenants) than to other, similarly situated tenants in
private housing. Tenants argue that PHA violated their rights to
privacy under the California Constitution and that any use of the
juvenile court records violates their rights to equal protection,
due process, and the uniform application of laws.
