California, United States of America
The following excerpt is from White v. Cnty. of L. A., B254503 (Cal. App. 2016):
an officer, including decisions that do not constitute discipline or punitive action." (Id. at p. 926.) Therefore, "regardless of whether the employing agency contemplates or has rejected further action regarding an adverse comment made against a peace officer employee, the officer is entitled to disclosure of the comment if it is entered in an agency file used for a personnel purpose." (Ibid.; see also Seligsohn v. Day (2004) 121 Cal.App.4th 518, 530 [in determining whether a document is subject to disclosure under Government Code section 3305, "what is relevant is not whether the document will serve or has served as a basis for disciplinary action but whether it may serve such a function"].)
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