In what circumstances will a court order suppression of statements made by a police officer under section 3303 of the Civil Procedure Code?

In Hanna v. City of Los Angeles (1989) 212 Cal.App.3d 363, 367, 260 Cal.Rptr. 782, the court held suppression was warranted as a remedy for multiple violations of section 3303. The violations included denial of the police officer's request for representation, denial of access to a tape recording of his first interrogation prior to his second interrogation, and denial of access to investigative reports. ⁴ (Id. at p. 370, 260 Cal.Rptr. 782.) The investigators also disregarded the officer's procedural rights in an effort to expedite [57 Cal.App.4th 1517] the investigative process before the officer received tenure. (Id. at p. 371, 260 Cal.Rptr. 782). The court concluded that these multiple violations may have affected the content of the officer's statements because the officer may have been " ' "too fearful or inarticulate to relate accurately the incident being investigated, or too ignorant to raise extenuating factors" ' [citation]...." (Id. at p. 374, 260 Cal.Rptr. 782.) In addition, having a representative present and a recording made of the interrogation may have helped the officer to support his position, as the court also found that the investigators' version of the officer's statements may have been affected. (Ibid.) Consequently, the court held suppression of the statements was warranted. (212 Cal.App.3d at p. 375, 260 Cal.Rptr. 782.)