In Association for Los Angeles Deputy Sheriffs v. Superior Court, the Supreme Court holds a confidentiality statute does not prevent law enforcement agencies from disclosing to prosecutors the identity of an officer who is a potential witnesses in a criminal prosecution and whose personnel file includes possibly impeaching or exonerating information that criminal defendants are constitutionally entitled to. The information could include instances of bribery, evidence tampering, unreasonable force, or domestic violence.
The unanimous opinion by Chief Justice Tani Cantil-Sakauye concludes that the officer names are confidential under the pertinent statutes, but that sharing those names with prosecutors does not violate confidentiality. The court says that interpreting the statutes to prohibit the limited disclosure “would pose a substantial threat” to compliance with a constitutional obligation to inform defendants of evidence favorable to them. The opinion is also the court’s first pass at discussing SB 1421, under which, the court explains, “certain records related to officer misconduct are not confidential.”
The court reverses a divided decision by the Second District, Division Eight, Court of Appeal.
Maura Dolan reports in the Los Angeles Times on today’s decision: “California Supreme Court backs greater access to police misconduct cases.”