County of Sonoma v. Pub. Employment Relations Bd.

BACKGROUND

In 2016, the Board enacted an ordinance creating IOLERO to provide “objective, independent and appropriate review and audit of law enforcement administrative investigations, which include allegations of misconduct” by the Sheriff. Among other things, the ordinance authorized IOLERO to provide advice and recommendations regarding law enforcement policies and procedures, and to perform independent audits of internal departmental investigations regarding officer use of force incidents, incidents of misconduct, and corrective action taken. IOLERO was also empowered to receive and review citizen complaints and forward them to the Sheriff. (Former SCC, § 2-394, subd. (b)(1).) In addition, IOLERO could “[a]dvise if investigations appear incomplete or otherwise deficient and recommend further review as deemed necessary; when warranted, propose independent recommendations or determinations regarding investigations.” (Id., subd. (b)(4).) But the ordinance prohibited IOLERO from conducting “its own investigation of complaints against law enforcement personnel,” compelling

3 “by subpoena the production of any documents or the attendance and testimony of any witnesses,” or…