California Supreme Court

Assn. for L.A. Deputy Sheriffs v. Superior Court

August 26, 2019

Summary

The California Supreme Court held that a law enforcement agency may disclose to prosecutors, when an officer is a potential witness in a pending criminal case, that the officer may have exonerating or impeaching material in a confidential personnel file. Although the Brady list was confidential insofar as it was derived from confidential records, the Pitchess statutes permit this limited disclosure because it facilitates the prosecution's constitutional disclosure obligations. The court reversed the Court of Appeal and remanded for further proceedings.