Berkeley Police Ass'n v. City of Berkeley

The Berkeley Police Review Commission (PRC) investigates citizen complaints against Berkeley police officers and holds evidentiary hearings on the complaints that are open to the public. The Berkeley Police Association (BPA) filed a petition for writ of mandate against the PRC and the City of Berkeley (collectively, Berkeley) alleging, among other things, that the PRC had a duty to (1) maintain the confidentiality of its investigatory records and findings and close its evidentiary hearings to the public, in accordance with Penal Code 1 section 832.7; and (2) afford all officers subject to PRC investigations and hearings all rights and protections provided by the *389 Public Safety Officers Procedural Bill of Rights Act (Gov. Code, § 3300 et seq.) (PBRA). The trial court granted BPA’s petition on both issues. We affirm.

I. BACKGROUND

A. Trial Court Proceedings

BPA filed this challenge to the PRC’s citizen complaint procedures in July 2002. The petition alleged, among other things, that the PRC’s investigative and public hearing process violated the confidentiality of police officer personnel records under section 832.7, and failed to provide officers with the full…