A recent state appellate court ruling in the divorce of a Los Angeles billionaire has declared a California statute unconstitutional because it allows spouses to seal entire documents from public view.

Ron Burkle, chairman of Yucaipa Cos., an investment firm that owns grocery chains including Wild Oats Market and Pathmark Stores Inc., is the first to use the 2004 statute by sealing 28 documents in his divorce from Janet Burkle.