Court Weighs in on Police Union's Claims

Case: Santa Ana Police Officers Association v. City of Santa Ana
Court: California Court of Appeal, Fourth District, Division Three
Date: February 28, 2025
Citation: 109 Cal.App.5th 296

In a notable decision, the California Court of Appeal delivered a split ruling in a lawsuit brought by the Santa Ana Police Officers Association (SAPOA) and unnamed officers (the "Doe Officers") against the City of Santa Ana, following the alleged unlawful release of confidential police personnel records to a media outlet.

The case arose after the Voice of OC, a local news organization, obtained information from the City about officers placed on paid administrative leave between 2016 and 2021. SAPOA alleged that the release included private personnel data in violation of California laws governing police record confidentiality. The City later asked the outlet to return the documents, but no further action was taken.

SAPOA brought four claims: (1) unlawful disclosure of personnel records; (2) negligence; (3) failure to investigate a citizen complaint about the disclosure; and (4) failure to provide information in violation of the Meyers-Milias-Brown Act (MMBA), California’s public sector labor law.

The appellate court issued a mixed ruling:

• Doe Officers Dismissed: The court ruled the anonymous officers could not proceed pseudonymously without statutory authority or court approval. Their claims were dismissed outright for violating procedural rules.

• No Private Right of Action for Disclosure: The court reaffirmed that state confidentiality statutes (Penal Code § 832.7 and Evidence Code §§ 1043–1045) do not create a private right to sue for damages or injunctive relief based on past disclosures. As such, SAPOA’s first and second causes of action were dismissed.

• Failure to Investigate Claim Revived: The court revived SAPOA’s third cause of action, holding that under Penal Code §§ 832.5 and 832.7(f), the City had a ministerial duty to investigate complaints and inform complainants of the results. Relying on Galzinski v. Somers (2016), the court ruled that SAPOA adequately stated a claim for mandamus relief.

• MMBA Claim Fails for Lack of Exhaustion: The court affirmed dismissal of SAPOA’s MMBA claim, noting that as a union—not individual peace officers—it was required to first seek relief through the Public Employment Relations Board (PERB), which it had not done.



Bottom Line: The decision underscores both the procedural hurdles for anonymous litigants and the limited remedies available under California’s police record confidentiality laws. However, it affirms that police unions can seek court intervention when cities fail to investigate complaints as required by statute.

John Hagan is a Certified Law Clerk at KC Law Group, assigned to the administrative and criminal defense practice groups. He is a third-year law student at Trinity Law School in Orange County, California.