EEOC v. County of San Benito
In EEOC v. County of San Benito, 818 F. Supp. 289, (N.D. Cal. 1993), a federal district court ordered a county to comply with a subpoena by the EEOC in holding that "federal Equal Employment Opportunity Commission's mandates preempt state restrictions" and that California's confidentiality laws relating to peace officers do not provide a basis for declining to comply with the Commission's subpoenas. Id. at 291.
This ruling is helpful in establishing the right to confidential peer review documents.