San Diego County Reinstated in Lawsuit Over Deputy’s Misuse of Victim Data

Appellate Court Ruling Restores County Liability

According to a decision issued on Monday by a three-justice panel of the Fourth District Court of Appeal, a jury should decide whether Wilson acted within the scope of his employment when he repeatedly checked the confidential files. In 2024, San Diego Superior Court Judge Matthew Braner granted summary judgment for the county, ruling that Wilson’s actions were personal and outside his job duties. However, the appellate panel found that because accessing such records was a regular part of Wilson’s job, a reasonable jury could conclude the misuse was a foreseeable risk of the broad access granted by the agency.

“A jury could conclude that the access of Wilson to the investigative file of Jane Doe was reasonably related to the functions that the county entrusted to custody deputies,” the appellate panel wrote in its opinion. Joseph McMullen, an attorney representing the plaintiff known as Jane Doe, told the San Diego Union-Tribune that the ruling sends the case back to the trial court to proceed toward a jury trial.

Timeline of the Offense and Unauthorized Record Searches

The case originates from a 2018 incident when Wilson, who was off-duty at the time, groped the 14-year-old girl inside a fast-food restaurant in Vista, according to court documents cited by the appellate court. Following the assault, details of the victim were provided to sheriff’s investigators. Court records show Wilson subsequently searched the confidential investigation file at least 44 times, downloading photographs of the victim and looking up her home address.

Judge Braner’s initial ruling stated that Wilson accessed the files because he feared being identified as the perpetrator and wanted to track the progress of the investigation to evade detection. Wilson was criminally prosecuted, pleaded guilty, and received a one-year jail sentence in October 2018, alongside a mandatory requirement to register as a sex offender.

Next Steps in San Diego Superior Court

McMullen stated to the San Diego Union-Tribune that evidence in the case indicates custody officers routinely browsed confidential investigative files for entertainment, and that the sheriff’s department possessed the technology to restrict such access but chose not to deploy it. The appellate panel noted that the department relied primarily on policies rather than technical blocks to prevent misuse.

San Diego County did not respond to requests for comment regarding the appellate decision. No new hearing dates had been scheduled in the San Diego Superior Court as of Tuesday.