Supreme Court of California

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Poole v. Orange County Fire Authority, S215300

The Firefighters Procedural Bill of Rights Act, Gov. Code section 3250 et seq., which gives a firefighter the right to review and respond to any negative comment that is "entered in his or her personnel file, or any other file used for any personnel purposes by his or her employer," does not give an employee the right to review and respond to negative comments in a supervisor's daily log, consisting of notes that memorialize the supervisor's thoughts and observations concerning an employee, which the supervisor uses as a memory aid in preparing performance plans and review, because the log was not shared with or available to anyone other than the supervisor who wrote the log.

Appellate Information

  • Decided 08/24/2015
  • Published 08/24/2015




  • Supreme Court of California