Santa Ana Police Officers Assn. v. City of Santa Ana

INTRODUCTION

The Santa Ana Police Officers Association (SAPOA) and certain anonymous City of Santa Ana police officers, suing pseudonymously1 as Doe Officers,2 appeal from a judgment entered after the trial court sustained without leave to amend the demurrer of defendant City of Santa Ana (the City) to Plaintiffs’ first amended complaint. Plaintiffs alleged the City had wrongfully disclosed the Doe Officers’ confidential personnel records, failed to conduct an investigation in response to a citizen complaint brought by the SAPOA about that disclosure, and denied Plaintiffs’ request for copies of communications regarding that disclosure. Plaintiffs’ first amended complaint incorporated those allegations into four causes of action. In the first cause of action, Plaintiffs asserted the alleged disclosure of confidential personnel records violated Penal Code section 832.7 and Evidence Code sections 1043 and 1045. In the second cause of action, Plaintiffs asserted the City was negligent in disclosing those records. In the third cause of action, Plaintiffs asserted the City’s alleged failure to conduct an investigation of the SAPOA’s complaint constituted a violation of Penal Code…