Is there an exemption or privilege for disclosure of records of investigations of complaints against police officers under section 832.8 of the Penal Code?

The court in City of Hemet held that Penal Code sections 832.5 through 832.8 create an exemption or privilege for records of investigations of complaints against an officer under section 6254, subdivision (k). (City of Hemet v. Superior Court, supra, 37 Cal.App.4th at pp. 1422-1423, 44 Cal.Rptr.2d 532.) The court explained that Evidence Code section 1043 et seq. constitutes the exclusive means for discovery of these records by a litigant in a civil action. (Id., at pp. 1423-1425, 44 Cal.Rptr.2d 532.) In particular, the court held that Penal Code section 832.7 "establishes a general condition of confidentiality which falls directly within the scope of the exemption created by Government Code section 6254, subdivision (k), for records 'the disclosure of which is exempted or prohibited pursuant to federal or state law.' The following clause, relating to disclosure in judicial proceedings, merely creates a limited exception to the general principle of confidentiality."

Page 413