Arizona Revised Statutes
Ariz. Rev. Stat. § 38-1109 (2026)
Confidentiality of records; exception
✓ current as of May 2026
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38-1109. Confidentiality of records; exception
A. An employer shall not include in that portion of the personnel file of a law enforcement officer that is available for public inspection and copying any information about an investigation until the investigation is complete or the employer has discontinued the investigation.
B. If the law enforcement officer has timely appealed a disciplinary action, the investigation is not complete until the conclusion of the appeal process. This subsection does not apply to a law enforcement officer who is employed by an agency of this state as an at will employee.
Notes of Decisions
Cited in 2
cases (2 in the last 5 years), 2024–2024 · leading case: Melendres v. Skinner (D. Ariz. 2024).
Melendres v. Skinner (D. Ariz. 2024). “8 A.R.S. § 38-1109(A). Any information about the investigation is excluded from that part 9 of the personnel file of a law enforcement officer that is available for public inspection 10 “until the investigation is complete or the employer has discontinued the investigation.”
Melendres v. Skinner (D. Ariz. 2024). “8 A.R.S. § 38-1109(A). Any information about the investigation is excluded from that part 9 of the personnel file of a law enforcement officer that is available for public inspection 10 “until the investigation is complete or the employer has discontinued the investigation.”
— Ariz. Rev. Stat. § 38-1109(A) — 2 cases
Melendres v. Skinner (D. Ariz. 2024). “8 A.R.S. § 38-1109(A). Any information about the investigation is excluded from that part 9 of the personnel file of a law enforcement officer that is available for public inspection 10 “until the investigation is complete or the employer has discontinued the investigation.”
Melendres v. Skinner (D. Ariz. 2024). “8 A.R.S. § 38-1109(A). Any information about the investigation is excluded from that part 9 of the personnel file of a law enforcement officer that is available for public inspection 10 “until the investigation is complete or the employer has discontinued the investigation.”
— Ariz. Rev. Stat. § 38-1109(B) — 2 cases
Melendres v. Skinner (D. Ariz. 2024). “8 A.R.S. § 38-1109(A). Any information about the investigation is excluded from that part 9 of the personnel file of a law enforcement officer that is available for public inspection 10 “until the investigation is complete or the employer has discontinued the investigation.”
Melendres v. Skinner (D. Ariz. 2024). “8 A.R.S. § 38-1109(A). Any information about the investigation is excluded from that part 9 of the personnel file of a law enforcement officer that is available for public inspection 10 “until the investigation is complete or the employer has discontinued the investigation.”
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