3. 911 tapes.

911 tapes are not expressly exempt under the CPRA.  Arguably, when calls for assistance involve an allegation of criminal wrongdoing, they may fall under the investigatory records exemption of Section 6254(f).  Under such circumstances, the detailed information culled from the tape and required to be disclosed under the statute would have to be disclosed, but not the tape itself. Cal. Gov’t Code § 6254(f)(1), (2) and (3).  However, not all calls to a 911 call center or local police department are or should be protected from disclosure under this provision. Section 6254(f) exempts only “[r]ecords of complaints to, or investigations conducted by, or records of intelligence information or security procedures of” various law enforcement agencies, as well as certain “investigatory . . . files” maintained by those agencies.  Cal. Gov’t Code § 6254(f).  In Haynie v. Superior Court, 26 Cal. 4th 1061, 1071, 112 Cal. Rptr. 2d 80, 31 P.3d 760 (2001), the California Supreme Court made clear that this exemption must not be interpreted to “shield everything law enforcement officers do from disclosure.”  The Court emphasized that “officers make inquiries of citizens for purposes . . . that are unrelated to either civil or criminal investigations.”  Id.  “The records of investigation exempted under section 6254(f) encompass only those investigations undertaken for the purpose of determining whether a violation of law may occur or has occurred.”  Id. (emphasis added).  When a 911 call is made for medical assistance, for example, Section 6254(f) arguably is not implicated.