City of Los Angeles v. Superior Court

Opinion

KENNARD, J.

Defendant Jeremy Brandon, who was charged with sexually molesting a seven-year-old boy, sought discovery of certain information in the personnel records of the two arresting officers. The trial court reviewed the materials in chambers and, as relevant here, ordered the disclosure of a citizen complaint filed against one of the officers 10 years before the arrest in this case. Although Evidence Code section 1045, subdivision (b)(1) expressly precludes discovery of citizen complaints “occurring more than five years before” the accused’s criminal act, the Court of Appeal upheld…