Across about six months, five CPRA requests on this case closed with conclusory search results that named no system searched, no custodian, and no record-specific withholding basis.
When a city closes a public-records request, a bare “we’re done” can be hard to test if the record later turns out to be incomplete. Over about six months the property owner’s representative sent the city five separate records requests about this one case. R.25-3549 R.26-39 R.26-71 R.26-1061 R.26-1549 Each one came back the same way: a short, conclusory sign-off — either “all responsive records have been provided” or “the city has no records” — that named no computer system it searched and no person who ran the search. On three of the five closings the city pasted in the same two-line “exempt categories” note word for word; R.26-71 R.26-1061 R.26-1549 on the other two it used a slightly different note or none at all — but none of them tied a specific withheld record to a specific reason. GC §7927.705 GC §7930.100 On one request the owner’s representative explicitly wrote and asked the city to “indicate which systems and custodians are being searched,” R.25-3549 and the closing answer still didn’t say. That repeated, identical-shaped non-answer only becomes visible once you line up all five requests side by side, which is exactly what the records portal made possible. R.25-3549 R.26-39 R.26-71 R.26-1061 R.26-1549
Bottom line: five times over about six months the city closed records requests with a one-line “we’re done” — never naming what it searched or who searched it — and on one request it gave that non-answer even after being asked in writing to name the systems and custodians.Five Case 23-009185 CPRA requests share the same closure problem. The City closed them with broad conclusions — either “all responsive records have been provided” or “no records responsive” — without identifying what system was searched, who searched it, or what record-specific withholding basis applied. R.25-3549 R.26-39 R.26-71 R.26-1061 R.26-1549
This card does not claim that the CPRA always requires a formal search log. A full-production closure can be administrative shorthand. The problem is that these were targeted records questions, the requester asked in writing for systems and custodians on at least one request, R.25-3549 later portal records exposed contradictions or gaps, Card 33 Card 35 Card 36 Card 37 and the closures still gave only search conclusions rather than search accounts.
Three of the five closures recite the identical two-category exemption boilerplate verbatim; R.26-71 R.26-1061 R.26-1549 the other two recite a variant or, in the no-records close, none — but every one of the five leaves the search path undescribed. R.25-3549 R.26-39
Under the CPRA, any withholding or denial must identify the responsible official and the specific legal basis. An unexplained “all responsive records provided” or “no records” response becomes legally vulnerable when later records contradict it. GC §7922.540 GC §7922.000
R.25-3549 closed with “all responsive records have been provided” and generic exemption language, while itemized follow-ups received no item-by-item response. R.25-3549
R.26-1061 and R.26-1549 closed with the same “all documents that appear to be responsive” formulation and the same two exemption categories; R.26-71 carried the same boilerplate on closure. R.26-1061 R.26-1549 R.26-71 GC §7927.705 GC §7930.100
Pattern table: The five requests cover: (1) R.25-3549 — broad case-file CPRA; closed 11/07/2025 “all responsive records have been provided” plus generic exemption recital; no system, no custodian, no withheld-record identification. R.25-3549 (2) R.26-39 — proof of delivery/corrective record for disputed email-log statement; closed same day asserting no responsive records. R.26-39 (3) R.26-71 — raw 2025 Lovato note/log exports; deflected as “already produced,” then closed 03/26/2026 after five rolling extensions with verbatim boilerplate. R.26-71 (4) R.26-1061 — note exports for five other officers; closed 03/25/2026 with identical two-category boilerplate. R.26-1061 (5) R.26-1549 — April 2026 case-file production; closed 04/20/2026 with identical boilerplate. R.26-1549 None named a specific system, custodian, record-specific exemption basis, or responsible official.
The City’s strongest answer is that “all responsive records have been provided” can be a sufficient closure when nothing is withheld. That is true as far as it goes. However, R.26-39’s same-day “no records” closure was directly contradicted by the City’s own later production referenced in Card 33. R.26-39 The defect preserved here is narrower: five targeted requests on one case closed without naming the search path, and the absence became material because later productions and portal records exposed specific gaps. Three closures used the same two-category exemption boilerplate, R.26-71 R.26-1061 R.26-1549 GC §7927.705 GC §7930.100 and one no-records closure collided with the City’s own recent production. R.26-39 Card 33 This card preserves the pattern that the closure conclusions named no system, no custodian, and no record-specific basis across the five requests.