On July 14, 2026, I made the following Public Records Act request of the City of Visalia, and the Visalia Police Department:
Pursuant to the California Public Records Act (CPRA), California Government Code § 7920.000 et seq., I am writing to request copies of public records held by the City of Visalia and the Visalia Police Department (VPD) regarding the integration, access, sharing, or use of Automated License Plate Reader (ALPR) systems owned, operated, or deployed by certain private-sector entities.
Specifically, I request copies of all records, regardless of physical form or characteristics, from January 1, 2023, to the present, relating to the following three categories of private ALPR deployment:
1. Visalia Economic Development Corporation (VEDC) ALPR Systems
Agreements and Authorizations: Any Memorandums of Understanding (MOUs), contracts, operational agreements, data-sharing agreements, or software integration permissions allowing the Visalia Police Department (VPD) to access, receive, search, or query ALPR data, logs, “hot lists,” or real-time alerts generated by cameras owned, leased, or managed by the VEDC (including those deployed in the Visalia Industrial Park).
Correspondence: All correspondence (including emails, text messages, and written memos) between the City of Visalia officials, staff, or representatives, VPD personnel and representatives, contractors, or board members of the VEDC (including but not limited to Executive Director Bruce Nicotero) regarding the installation, funding, maintenance, or law enforcement usage of VEDC-managed ALPR cameras.
Locations: Physical location of all cameras to which VPD has been granted access.
2. Home Depot Corporation ALPR Systems
Data-Sharing & Integration: Any agreements, MOUs, API integration credentials, or authorizations (via third-party platforms such as Flock Safety, Vigilant Solutions, or similar vendors) enabling VPD to query or receive automatic alerts from ALPR/surveillance systems operating at or around the Visalia Home Depot location (located at 3500 W. Orchard Ave.).
Correspondence: All communications between City staff or VPD personnel and Home Depot corporate security, store management, or representing investigators concerning ALPR data access, direct feeds, or digital “hot list” coordination.
3. Lowe’s Corporation ALPR Systems
Data-Sharing & Integration: Any agreements, MOUs, API integration credentials, or authorizations enabling VPD to query or receive automatic alerts from ALPR/surveillance systems operating at or around the Visalia Lowe’s locations (located at 1400 S. Demaree St. and 3020 N. Demaree St.).
Correspondence: All communications between City Staff, VPD personnel, and Lowe’s corporate security, store management, or representing investigators concerning ALPR data access, direct feeds, or digital “hot list” coordination.
Format of Records: I request that these records be provided in their original electronic format (e.g., PDF, Excel, .msg, or .eml) to avoid unnecessary printing costs and to preserve metadata.
Fee Waiver/Limitation: If there are any administrative fees associated with searching or duplicating these records, please notify me before they are incurred. (As these records concern public safety technology oversight and civil liberties, they are in the public interest, and I request a waiver of any fees).
Severability and Redactions: If the City determines that certain portions of the requested records are exempt from disclosure (such as specific law enforcement investigative techniques under Gov. Code § 7923.600), please disclose all reasonably segregable, non-exempt portions of the records with appropriate redactions, accompanied by a written explanation citing the specific statutory exemption.
As provided by Government Code § 7922.535, I look forward to receiving your determination on this request within 10 days of receipt.
On July 28, 2026, I received this notice (a bit past their ten-day required response window):
To whom it may concern:
The Visalia Police Department is diligently working on your request. Per Government Code 7922.535(b) we will be utilizing the fourteen-day extension to fulfill your request. Thank you for your patience.
July 28, 2026, 4:42pm by Staff
Today, August 10, 2026, I received this email:
They’re still looking, by golly!
Lowe’s shopping center, on South Mooney Blvd, Visalia. Image from Deflock.org.
Lowe’s Shopping center, Riggin and Demaree, Visalia. Image from Deflock.org.
I don’t know if the Visalia Home Depot has cameras, but I’ve read they grant law enforcement access to those they do have, so I want to see if there’s an agreement with Home Depot about it.
More tick tock tick Flock.
As is my practice, here are the previous blog posts about Flock Automated License Plate Readers in Visalia, California.
Flock Me – Round 2
August 7, 2026
Jim Reeves commentary, geek, News, Personal ai, ALPR, Flock Camera, Flock License Plate Reader, License Plate Reader, News, politics, technology, visalia, visalia police department Leave a comment
In my post, “The Final Flock – and the answer is “NO”, the City of Visalia closed out my Public Records Request without providing all of the information I requested, citing privacy laws, and police department policy.
Sorry, that’s not good enough. I’m trying again. Today, August 7, 2026, I’ve filed the following supplemental Public Records Request:
“RE: Formal Public Records Request & Demand for Disclosure — Personal ALPR Data (Plate: JJRJR)
Supplemental to PRAR Dated April 24, 2026 / Response Dated August 3, 2026
Dear Custodian of Records and Ms. Berglund:
I am writing to formally request—and respectfully demand—the release of public records pursuant to the California Public Records Act (CPRA), California Government Code § 7920.000 et seq. This letter serves as a specific, narrow request following the supplemental response issued by Herr Pedersen & Berglund LLP on August 3, 2026 regarding my initial April 24, 2026 request.
1. Scope of Request
Pursuant to the CPRA, I request copies of all Automated License Plate Reader (ALPR) records, data files, metadata logs, and associated digital images captured or maintained by the Visalia Police Department (including fixed cameras and mobile units) that reference or identify the following California license plate registered to me:
2. Legal Basis and Response to Department Denials
The City’s August 3, 2026 response asserts that raw ALPR data is exempt under the CPRA balancing test (Gov. Code § 7922.000), cites Department Policy 428.2 stating ALPR data is “not open to public review,” and references Civil Code § 1798.90.55 regarding transfers to non-public agencies. Respectfully, these assertions misapply established California case law and statutory rules regarding individual requests for personal records.
A. Rejection of Blanket Exemptions (ACLU v. Superior Court)
In ACLU Found. v. Superior Court of Los Angeles County (2017) 3 Cal.5th 1032, the California Supreme Court explicitly held that routine ALPR data collection is not automatically exempt as an investigative record (Gov. Code § 7923.600) because the scans are indiscriminately gathered rather than generated for a targeted inquiry. Furthermore, the Court established that agencies cannot issue blanket denials or rely on generalized privacy claims to withhold all ALPR records.
B. Absence of Privacy Exemption for the Subject Citizen
The primary justification for withholding raw ALPR data under the CPRA balancing test (Gov. Code § 7922.000) is protecting the privacy of individual vehicle owners. However, when an individual requests their own vehicle’s records, the privacy interest belongs entirely to the requester. Releasing location records of license plate JJRJR to the registered owner of plate JJRJR poses zero invasion of personal privacy. The privacy protections of the CPRA exist to safeguard citizens from government intrusion, not to shield public agencies from disclosing non-sensitive records to the data subject.
C. Statutory Duty to Segregate and Disclose (Gov. Code § 7922.525)
California Government Code § 7922.525 mandates that “any reasonably segregable portion of a record shall be available for inspection by any person requesting the record after the deletion of the portions that are exempted by law.”
To the extent the Department contends that releasing raw database files might expose third-party details or systemic operational configurations, the law requires the Department to redact or segregate those exempt elements and release the non-exempt data points (i.e., timestamps, coordinates/locations, and images matching plate JJRJR).
D. Misapplication of Civil Code § 1798.90.55 and Internal Policy
Civil Code § 1798.90.55 prohibits ALPR operators from selling, sharing, or transferring ALPR information to commercial entities or non-public agency third parties for private commercial use. It does not override an agency’s statutory obligations under the CPRA to release records to a requesting citizen. Furthermore, local agency policy (such as VPD Policy 428.2) cannot supersede state statutory law or Supreme Court precedent.
3. Requested Action & Timelines
Because this request is narrow, limited strictly to a single license plate over a 30-day window, and involves an individual seeking their own vehicle data, it presents minimal administrative burden to locate and process.
Pursuant to California Government Code § 7922.535, please provide a determination within 10 calendar days of receipt of this letter as to whether the City will comply with this request. If the Department asserts that any portion of the requested 30-day dataset or images remains exempt, please cite the specific statutory exemption for each redacted or withheld portion and demonstrate how the public interest in withholding clearly outweighs the public interest in disclosure under Government Code § 7922.000.
Thank you for your prompt attention to this matter and your continued service to our community. I look forward to receiving your response and the responsive data files.”
We’ll see if that shakes loose my data stored on the Flock Automated License Plate Reader system employed by the Visalia Police Department. I’m crossing my fingers, but not holding my breath.
As in my previous posts, here are my blogs about the Flock adventure I’ve been on:
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