In Bradshaw v. City of Los Angeles (1990) 221 Cal. App. 3d 908, the court interpreted section 832.7 to mean that the statute did not apply to preclude a public entity from disclosing peace officer personnel records unless those records were sought in connection with a civil or criminal proceeding. In that case, a police officer alleged the city violated section 832.7 when it disclosed information to the news media about his public disciplinary appeal hearing. In evaluating whether this allegation stated a valid cause of action, the Bradshaw court noted that section 832.7 was susceptible to two different interpretations: (1) the Legislature intended the disclosure prohibition applied only to disclosures in the context of a civil or criminal proceeding; or (2) the Legislature intended to create a rule providing that all peace officer personnel records are confidential and then to recognize a specific exception to that rule for parties to obtain relevant information through Pitchess discovery procedures in the context of a civil or criminal proceeding. (Bradshaw v. City of Los Angeles, supra, 221 Cal. App. 3d at p. 916.) The Bradshaw court ultimately adopted the former interpretationthat section 832.7 applied to provide limitations only for peace officer personnel information disclosures in the context of a civil or criminal proceeding, and therefore the code section did not prohibit the city from disclosing information to the media concerning the officer's public administrative appeal hearing. (Bradshaw v. City of Los Angeles, supra, 221 Cal. App. 3d at pp. 916-920.) The court reasoned that section 832.7's legislative history showed that the specific purpose of the statute was to codify the Pitchess decision regarding discovery procedures for third party litigants to obtain relevant police personnel information, and not to establish general rules regarding the voluntary release of information to news media. (221 Cal. App. 3d at pp. 917-918.) The Bradshaw court alternatively held that the officer's claim was without merit because section 832.7 did not provide a private right of action for an individual officer to obtain damages caused by an improper disclosure. (221 Cal. App. 3d at pp. 918-919.)