On July 23, 2013, the First District of the California Court of Appeal held that police officer identities and ranks in investigative reports unrelated to discipline or personnel actions are discoverable under the Public Records Act.
In Federated University Police Officers Association v. Superior Court, several news outlets sought to discover an investigative report authored by a consultant to the University of California regarding the use of pepper spray by campus police during student protests at UC Davis in 2011. 14 officers were ordered by their chief to participate in interviews for the report, and were advised that information provided to the consultant would not be used in any disciplinary proceeding. No officers who were the target of citizen complaints or internal affairs investigations were interviewed. The report did not recommend discipline of any officer, and was directed at UC Davis administration-level decision-making. A related task force report concluded that several officers performed improperly, but did not recommend discipline. These reports were ultimately released to the news outlets with name and rank of involved officers redacted.