In Craig v. Municipal Court (1979) 100 Cal.App.3d 69, a defendant in a criminal case sought to show the propensity for violence of an officer when he made arrests. Defendant sought to discover the names of everyone the officer had arrested on similar charges during the preceding two years. The court reversed an order granting discovery, in part by invoking the constitutional right of privacy of those arrested to prevent such disclosure of records officially compiled with or without their consent. The custodian of the records was held to have standing to assert such a right on behalf of the absent arrestees.