Message from SHRM Inland Empire President Elect

As we move through 2026, HR’s role is expanding from managing people processes to designing the conditions where people can thrive. Human sustainability isn’t a trend it’s the next era of HR leadership.

IESHRM will continue bringing this conversation to our members through events, learning opportunities, and community engagement. Together, we can build workplaces that support long‑term success for both people and organizations.

Upcoming Event

LEADHR: Talent Wars — Winning Recruitment & Retention

August 20, 2026 | 8:30–10:30 AM | Riverside County Office of Education – Conference Center | 4280 Brockton Avenue, Riverside, CA 92501

Join us for a high‑impact LEADHR session focused on the competitive landscape of talent acquisition and retention. This program will explore modern strategies, data‑driven insights, and practical tools HR leaders can use to attract, engage, and retain top talent in today’s evolving workforce. Perfect for HR professionals at all levels looking to strengthen their talent strategy.

Meet the new Face of Our Emerging Professionals Program

IE SHRM is pleased to welcome Jenifer Patton to the Board of Directors as the new leader of our Emerging Professional Program. With a strong commitment to developing the next generation of HR professionals, Jenifer brings valuable experience, fresh perspective, and a passion for supporting early‑career talent. Jenifer holds a Master of Science in Human Resource Management and is a SHRM Certified Professional (SHRM-CP) and currently holds the role of Human Resources Analyst with San Bernardino Municipal Water.

In this role, Jenifer will guide programming, outreach, and engagement opportunities designed to help students and emerging HR practitioners build confidence, expand their networks, and grow in their careers. We are excited for the energy and leadership Jenifer will bring to this important initiative.

Please join us in welcoming Jenifer to the IESHRM Board. 

A Simple Check, A Big Difference for IE SHRM

Please remember to select IESHRM as your chapter on the SHRM website, as your support enables us to offer valuable and accessible programs.

Thank you to everyone for contributing to our shared success!

Laura Zamora
President Elect
SHRM Inland Empire Chapter

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Welcome New Members

Please join us in welcoming the newest members of SHRM Inland Empire! We’re proud to have you as part of our growing community of HR professionals and leaders. Your experience and perspective strengthen our chapter and support our shared commitment to advancing the people profession in 2026.

Welcome:

We’re excited to connect, collaborate, and grow together this year.

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SHRM Foundation Fundraising Event

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Legal News

On May 11, 2026, the California Fourth Appellate District, Division One, issued a decision in Voice of San Diego v. San Diego Unified School District concerning a petition for a writ of mandate filed by online news service Voice of San Diego (“Voice”) against the San Diego Unified School District (“SDUSD”).  Voice alleged SDUSD unlawfully delayed the disclosure of records under the California Public Records Act (“CPRA”) and brought a Code of Civil Procedure section 526(a) taxpayer cause of action, claiming SDUSD’s failure to timely issue CPRA determinations and produce documents were unlawful practices.  The case was initially filed in 2018 and litigated for a period of five years at the trial court level with Voice alleging SDUSD improperly processed 31 out of 75 CPRA requests over a five-year period.

The trial court and appellate court both denied Voice’s claims, holding that the CPRA does not define any specific timeframe to produce requested records.  The appellate court’s decision has been certified for partial publication, and offers valuable guidance for school districts and public agencies regarding how CPRA requests should be processed. 

The CPRA protects the fundamental right of “access to information concerning the conduct of the people’s business.”  (Gov. Code section 7921.000.)  It provides a two-step procedure for public agencies to respond to requests for public records.  First, within 10 days of receiving a CPRA request, a public agency must determine whether the request seeks disclosable records in its possession.  The agency must then “promptly” notify the requester of its determination, including its reasons for withholding any records, and provide an estimate of the date and time the records will be produced.  This 10-day timeline may be extended by 14 days when there are “unusual circumstances[,]” as defined.  (Gov. Code section 7922.535.)  In the determination, the agency is further required to “state the estimated date and time when the records will be made available” if the agency determined the CPRA request seeks disclosable public records.  (Gov. Code section 7922.535(a).)  Next, upon receipt of any required payment, such as copying costs, the agency must produce the records by making the records “promptly available” to the CPRA requester.  (Gov. Code section 7922.530.)

Voice alleged that SDUSD violated the CPRA by routinely taking several months to complete its disclosures in response to Voice’s CPRA requests.  Citing a federal Freedom of Information Act (“FOIA”) case, Voice argued that the duty to make records “promptly available” required agencies to produce records “within a few days or weeks.” 

The trial court and appellate court both disagreed.  The appellate court determined that while the CPRA describes its procedures in “exceptionally careful detail,” it does not include any language explicitly requiring disclosure within “days or weeks.”  The appellate court further observed that the FOIA case involved statutory construction of a determination-related timeline for purposes of allowing a FOIA requester to file suit, and not a FOIA records production timeline.  The court declined to create an explicit CPRA timeline for production where the Legislature had not.  It reasoned, “By choosing to state only generally that an agency shall make public records ‘promptly available’ upon payment of fees for their duplication, the Legislature has opted for a deliberately flexible term, not a fixed time frame.” 

The court further explained that the meaning of “promptly” must be determined on a case-by-case basis, considering the burden placed “on the particular agency by the particular request.”  (Emphasis added.) 

The decision in Voice of San Diego demonstrates that under the CPRA, the length of time taken to produce, or complete a rolling production of, records, is not subject to a one-size-fits-all deadline.  It states in clear terms that what constitutes prompt disclosure under the CPRA will depend on the circumstances of a particular request.  The decision further identifies appropriate factors to consider in assessing promptness including the “specificity and breadth of the request, the nature and location of the records sought, the volume of the data to be searched, the storage medium that must be accessed, the level of review required for any exemptions, and redactions, and the complexity of the request; as well as the size, scope and complexity of the business or activities of the agency responding to the request.” 

Moreover, when calculating the time taken to produce records in some of SDUSD’s 31 CPRA responses, the court considered that SDUSD disclosed records responsive to some requests in rolling productions.  The court’s reasoning supports that rolling productions can be a helpful tool for public agencies dealing with burdensome CPRA requests.  The appellate court further noted that some of Voice’s CPRA requests at issue in the litigation were “overbroad and vague” or failed to reasonably describe identifiable records, noting, “the time [SDUSD] spent working with Voice to revise the request cannot be attributed to [SDUSD].”  Voice also took issue with SDUSD’s CPRA practices more generally, arguing that employing a single CPRA officer who worked on fulfilling CPRA requests in batches of 10-12 requests at a time “ensures backlog and delay.”  The trial court credited SDUSD on these points, and the appellate court approved, finding SDUSD’s practices were “‘substantially the same’ as…numerous other unified school districts and local city governments.  This included employing a single CPRA officer to handle requests from initial review to production of records.”

If the decision in Voice of San Diego v. San Diego Unified School District is later certified for publication, it will provide citable legal authority for public agencies regarding their compliance with CPRA obligations in relation to the specific circumstances surrounding each particular CPRA request received. 

Should you have specific questions regarding the content of this Alert or your agency’s CPRA practices or specific responses to CPRA requests, please contact the authors of this Alert or your usual AALRR counsel. 

This AALRR publication is intended for informational purposes only and should not be relied upon in reaching a conclusion in a particular area of law. Applicability of the legal principles discussed may differ substantially in individual situations. Receipt of this or any other AALRR publication does not create an attorney-client relationship. The Firm is not responsible for inadvertent errors that may occur in the publishing process.

© 2026 Atkinson, Andelson, Loya, Ruud & Romo

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The HR Huddle

July 14, 2026  |  11:00 AM to 12:00 PM | Virtual (Zoom)
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The HR Huddle series is a valuable resource for HR professionals, offering a monthly deep-dive into the latest legal updates, trends, and best practices in employment law. This collaboration with the legal experts of AALRR equips HR professionals and business leaders with the knowledge to navigate the complexities of the workplace, ensuring they stay ahead in a field that's constantly evolving. In this series, here insights and best practices on topics related to compliance, policy-making, and employee relations, these webinars are designed to strengthen the skills necessary for the dynamic and demanding world of human resources.

The HR Huddle Occurs Every 2nd Tuesday.

There is NO COST TO YOU!

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