Key Takeaway:

City of Vallejo v. Superior Court (2025) 112 Cal.App.5th 565
A recent California appellate court decision has significant implications for the scope of SB 1421 (enacted in 2018), providing a broad reading to Penal Code § 832.7(b)(1)(A)(i) and its requirement for the disclosure of records relating to "an incident involving the discharge of a firearm at a person by a peace officer," even absent formal discipline or individualized shooting investigations.

What Happened:

• In 2020, a news outlet published allegations that Vallejo police officers celebrated shootings by bending their badge tips.
• The police department hired an independent investigator (former Sonoma County Sheriff Robert Giordano) to investigate the practice.
• Giordano’s 167-page report confirmed badge bending occurred after shooting incidents but did not find sufficient evidence it was celebratory. No discipline was imposed.
• The ACLU filed a CPRA request in 2022 seeking the report and related records; the City of Vallejo refused disclosure, and litigation ensued.

Court’s Ruling:

• The Court held that since the legislative intent behind SB 1421 was "to require transparency when it comes to officer shootings to foster greater public trust and confidence in law enforcement" a broad reading of Penal Code § 832.7(b)(1)(A)(i) was proper and necessitated disclosure of the records at issue here.
• The records at issue were public records and not confidential peace officer personnel records under Penal Code § 832.7(a).

What This Means for You:

Under this decision, records relating to a peace officer discharging a firearm at an individual are likely to be treated as public records under the CPRA, even if no formal discipline was imposed as a result of the investigation at issue.

 

Summer Associate Brian Castro contributed to this article.