McMahon

Government Code section 3306.5, part of the Public Safety Officers Procedural Bill of Rights Act (POBRA), grants covered officers the right “to inspect personnel files that are used or have been used to determine that officer’s qualifications for employment, promotion, additional compensation, or termination or other disciplinary action.” (Gov. Code, § 3306.5, subd. (a).) Appellant Walter McMahon, employed as an officer in the Los Angeles Police Department (Department), was the subject of approximately 20 citizen complaints. The Department’s internal affairs investigation into those complaints determined they were all meritless, having been filed in bad faith by residents who were upset with the officer’s successful antigang efforts in and around the Imperial Courts housing project, where he regularly patrolled. The Department resolved all the complaints in favor of Officer McMahon, determining the officer was either exonerated or the allegations were unfounded. Although the Department provided Officer McMahon with the opportunity to review each of the complaints and various related documents and findings, the officer demanded to review additional materials from the…