Oakland Police Officers' Association v. City of OaklandAnnotate this Case
A complaint alleged that officers violated a citizen’s rights while conducting a mental health welfare check. Following an internal investigation, they were cleared of misconduct. The Oakland Community Police Review Agency (CPRA), a civilian oversight agency with independent authority to investigate police misconduct, conducted its own investigation. Before CPRA’s formal interrogation of the officers, their counsel demanded copies of all “reports and complaints” prepared or compiled by investigators, citing the Public Safety Officers Procedural Bill of Rights Act, Government Code section 3303(g). CPRA refused to disclose these materials and determined that officers knowingly violated the complainant’s civil rights by entering the residence and seizing property without a warrant, then actively concealed the violation. Based on the failure to disclose the requested material, the trial court ordered the city to disregard the interrogation testimony in any disciplinary proceedings against the officers.
The court of appeal reversed. Mandatory disclosure of complaints and reports before any interrogation of an officer suspected of misconduct is inconsistent with the statute's plain language and undermines a core objective—maintaining the public’s confidence in the effectiveness and integrity of law enforcement agencies by ensuring that internal investigations into officer misconduct are conducted promptly, thoroughly, and fairly. Under section 3303(g), an investigating agency’s disclosure obligations should be guided by whether the agency designates otherwise discoverable materials as confidential. Confidential materials may be withheld pending the investigation and may not be used as the basis for disciplinary proceedings absent disclosure; nonconfidential material should be disclosed upon request.