b. Rules for closed investigations.

Exempt. The CPRA’s exemption for investigatory files does not terminate when the investigation terminates. Williams v. Superior Court, 5 Cal. 4th 337, 362, 852 P.2d 377, 19 Cal. Rptr.2d 882 (1993). In Williams, the California Supreme Court held that the language and history of Section 6254(f) did not support an interpretation that would place a time limit on the duration of the exemption to disclosure regarding investigatory files. Additionally, the exemption has been held to apply to letters prepared after the conclusion of an investigation but that were related exclusively to the investigation. Rackauckas v. Superior Court, 104 Cal. App. 4th 169, 179, 128 Cal. Rptr. 2d 234 (2002).

The mandatory disclosure requirements of information from investigatory record, set forth above, have been held to apply only to those records pertaining to contemporaneous police activity, not to closed investigations. County of Los Angeles v. Superior Court (Kusar), 18 Cal. App. 4th 588, 598-99, 22 Cal. Rptr. 2d 409 (1993),