Ass'n for L.A. Deputy Sheriffs v. Superior Court of L.A. Cnty.

I. FACTUAL AND PROCEDURAL HISTORY

A. The Brady List

In late 2016, the Association counted among its members approximately 7,800 deputy sheriffs. The Department sent a letter to roughly 300 of those deputies, informing them that a review of "individual employees' personnel records" had "identified potential exculpatory or impeachment *326 information in your personnel file." Among other things, the letter served to "remind" deputies "about the existence of this material."

According to the letter, "[e]xamples of performance deficiencies" that qualify as potential Brady material "include, but are not limited to, founded administrative investigations involving violations of" any of nearly a dozen sections of the Department's Manual of Policy and Procedures. Those sections concern:

**240 (1) "Immoral Conduct"; (2) "Bribes, Rewards, Loans, Gifts, Favors"; (3) "Misappropriation of Property"; (4) "Tampering with Evidence"; (5) "False Statements"; (6) "Failure to make Statements and/or Making False Statements During Departmental Internal Investigations"; (7) "Obstructing an Investigation/Influencing a Witness"; (8) "False Information in Records"; (9) "Policy of Equality -…