In Pasadena Police Officers Assn. v. City of Pasadena (1990) 51 Cal. 3d 564, the Supreme Court addressed whether a peace officer who was the subject of an internal police department investigation into suspected officer misconduct was entitled by section 3303 to review the reports and complaints before being interrogated about the allegations. (Id. at pp. 568-569, 571.) The court held the statute does not compel preinterrogation discovery. (Id. at p. 579.) In addition to observing that the statutory language does not demonstrate an intent to grant the right to discovery of reports and complaints before an officer's interrogation (id. at pp. 576-577), the court noted that preinterrogation discovery is not fundamental to the fairness of an investigation and could frustrate the effectiveness of the interrogation. (Id. at pp. 578-579.)