SNEED vs COUNTY, et al.

A Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) is required to be signed by each party, the private court reporter, and the Judge prior to the hearing, if not using a reporter from the Court’s Approved Official Reporter Pro Tempore list.

Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver

25CV028810: SNEED vs COUNTY, et al. 06/17/2026 Hearing on Motion to Seal Death Certificate and Protection Order in Department 8D

and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk will forward the form to the Court Reporter’s Office and an official reporter will be provided.

The notice of motion does not provide notice of the Court’s tentative ruling system, as required by Local Rule 1.06(D). Plaintiff in pro per is directed to contact opposing counsel forthwith to advise of Local Rule 1.06, the Court’s tentative ruling procedure, and the manner to request a hearing. If Plaintiff is unable to contact opposing counsel prior to the hearing, Plaintiff shall be available at the hearing, in person or remotely, in the event opposing counsel appears without following the procedures set forth in Local Rule 1.06(B).

TENTATIVE RULING:

Plaintiff in pro per Shiena Sneed’s (“Plaintiff”) application to redact records is DENIED in part and GRANTED in part as follows.

Plaintiff moves for an order redacting Decedent Paul T. Williams’ death certificate. Plaintiff attached the unredacted death certificate to a Declaration of Successor in Interest, in which Plaintiff asserts that she is Decedent’s sister. Plaintiff moves to redact Decedent’s social security number, cause and manner of death, and location of remains, which Plaintiff argues is private information that serves no legitimate public interest in remaining accessible.

The redacted document actually filed with the Court, however, would redact Decedent’s birth date, educational details, and other information, in addition to the social security number, cause and manner of death, and location of remains. Court records are presumed to be open, and the party moving to seal records must demonstrate that the “proposed sealing is narrowly tailored.” (Cal. Rules of Court, rule 2.550.) Because the proposed redacted document does not match the relief Plaintiff requested in her motion, the Court DENIES Plaintiff’s motion in so far as it seeks the Court’s approval of the proposed redacted document.

Further, Defendant City of Sacramento (“Defendant”) argues in opposition that Plaintiff cannot assert privacy rights on behalf of a deceased person. (Opp., at p. 2:10–21.) The Court does not fully agree. California courts recognize that family members may properly assert the privacy interests of a decedent in some circumstances. (Catsouras v. Dept. of Cal. Highway Patrol (2010) 181 Cal.App.4th 856, 864.) That said, the Court agrees with Defendant that the manner of Decedent’s death is at issue in Plaintiff’s

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV028810: SNEED vs COUNTY, et al. 06/17/2026 Hearing on Motion to Seal Death Certificate and Protection Order in Department 8D

case, which asserts causes of action for wrongful death and medical negligence.

Plaintiff argues that the manner of death is protected as confidential by Health and Safety Code section 103526 and Welfare and Institutions Code section 5328. (Reply, at pp. 4:19–5:3.) Section 103526 restricts the release of certified copies of death certificates to “authorized person[s].” (Health & Saf. Code, § 103526, subd. (a), (c).) But this statute allows the release of death certificate to non-authorized persons, so long as the certificate is marked “informational, not a valid document to establish identity.” (Id., subd. (b).)

Section 5328 is part of the Lanterman-Petris-Short Act, dealing generally with voluntary and involuntary commitment of people with mental health disorders. (Welf. & Inst. Code, § 5000 et seq.) Section 5328 makes confidential “information and records obtained in the course of providing services to voluntary or involuntary recipients of services” in specific factual circumstances. (Id., § 5328, subd. (a).) The Court fails to see the relevance of Section 5328 on the information before the Court.

However, Defendant does not appear to oppose redacting the location of Decedent’s remains. (See Opposition, at p. 2:5–7.) Decedent’s social security number should not be available for public view in any case. (Cal. Rules of Court, rule 1.201.) The Court therefore GRANTS Plaintiff’s motion to redact as to the social security number and location of remains only.

Pursuant to California Rules of Court, rule 2.550, the Court finds that Decedent’s social security number and the location of Decedent’s remains are private and sensitive personal identifying information. Public release of this information would serve little or no public purpose. The Court finds that the privacy interest in this information overcomes the right of public access to the information, the privacy interest supports sealing, there is a substantial probability that the interest will be prejudiced without sealing, the sealing is narrowly tailored, and there is no less restrictive means to achieve the privacy interest.

Plaintiff is directed to refile her Declaration of Successor in Interest with Decedent’s death certificate redacted according to this order. Plaintiff shall provide the clerk a copy of this order when she refiles the appropriate papers.

The clerk is directed to promptly change the security clearance and remove from public view the “Amended Declaration of Successor in Interest” filed by Plaintiff on January 12, 2026.

This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc., § 1019.5; Cal. Rules of Court, rule 3.1312.)