Two new Court of Appeal decisions are chipping away at the confidentiality safeguards for peace officers’ personnel files under Pitchess v. Superior Court (1974) 11 Cal.3d 531. These rulings expand disclosure requirements and limit protective orders, potentially exposing officers to broader scrutiny and misuse of sensitive information. For public safety unions and officers, this signals a shifting landscape where traditional protections are giving way to demands for transparency. Below, we break down the cases and their combined implications.
In Schneider v. Superior Court (2025) 111 Cal.App.5th 613, the Second District Court of Appeal addressed a murder defendant’s motion for discovery of Brady material in the personnel files of six LASD deputies involved in the investigation. The trial court found Brady material in four files but limited disclosure to names, addresses, and phone numbers of complainants and witnesses—standard under classic Pitchess practice.
The appellate court reversed, holding that when material qualifies as Brady (favorable to the defense and material to guilt or punishment), the prosecution must disclose the full records, including documents, reports, and audio-visual evidence. This bypasses the usual Pitchess limitation, as Brady’s constitutional mandate trumps officers’ privacy...
