The Panel has reviewed the laws of other states that govern the disclosure of police disciplinary files. Many states provide public access to police disciplinary files far beyond what police departments in New York are permitted or required to disclose. Thirteen states have laws specifically designating internal police records as open to the public. Fifteen states disclose only some police disciplinary files or require a balancing of the officer’s privacy interest and the public interest to determine whether disclosure is permitted. Twenty-two states, including New York, largely preclude disclosure of police disciplinary files, mostly through exemptions in their freedom-of-information laws applicable to all personnel records. Within this group, only New York and Delaware also explicitly restrict access to internal police records. Delaware’s statute, titled the “Law-Enforcement Officers’ Bill of Rights,” specifically mandates that all records compiled in any internal investigation of an officer “shall be and remain confidential and shall not be released to the public.” California, long among the most restrictive states, late last year amended its applicable law to designate as public certain records of police misconduct.
 These states are: Alabama (Ala. Code § 36-12-40); Arizona (Ariz. Rev. Stat. Ann. §§ 39-121-28, 38-1109); California (Cal. Pen. Code § 837.2); Connecticut (by court ruling in Perkins v. Freedom of Information Comm’n, 228 Conn. 158 (1993)); Florida (Fla. Stat. § 119.01 et seq.); Georgia (Ga. Code Ann. § 50-18-72(a)(8)); Maine (Me. Rev. Stat. tit. 30-a, §§ 503(1)(B)(5), 2702(1)(B)(5); Me. Rev. Stat. tit. 5, § 7070(2)(E)); Minnesota (Minn. Stat. § 13.43); North Dakota (N.D. Cent. Code § 44-04-18); Ohio (Ohio Rev. Code Ann. § 149.43); Utah (Utah Code Ann. § 63G-2-301(3)(o)); Washington (Wash. Rev. Code § 42.56.001 et seq.); Wisconsin (Wis. Stat. § 13.36(10)(b)); see also Is Police Misconduct a Secret in Your State?, WNYC (Oct. 15, 2015), https://www.wnyc.org/story/police-misconduct-records/ (last visited Jan. 19, 2019).
 See, e.g., Mich. Sustained Comp. Laws §§ 15.243 § 13(1)(s)(ix) (allowing exemptions from release for personnel records of law enforcement agencies only if “the public interest in disclosure outweighs the public interest in nondisclosure”); Ark. Ann. Code § 25-19-105(c)(1) (permitting disclosure of records pertaining to an officer’s suspension or termination when a “compelling public interest” in disclosure is present); Hawaii Uni. Information Practices Act § 92F-14 (permitting disclosure of records pertaining to an officer’s dismissal); Ind. Code. § 5-14-3 (disciplinary records pertaining to an officer’s demotion, suspension, or discharge are public); Okla. Open Records Act § 51‑24A.7 (declaring police personnel records confidential unless they related to “final disciplinary action” resulting in loss of pay, suspension, demotion, or termination).
 Del. Code Ann. tit. 11, § 9200(c)(12).
 The Delaware statute appears even more restrictive than its New York counterpart. Unlike Civil Rights Law § 50–a, the Delaware law contains no exemption for disclosure by and to government agencies for conduct of official government functions. See Civ. R. L. § 50–a(4). The Delaware statute also contains a provision prohibiting disclosure in civil litigation unless the subject officer is being sued for misconduct causing injury. Del. Code Ann. tit. 11, § 9200(d). Courts have noted that the Delaware statute evinces “a strong public policy . . . favoring the confidentiality of police personnel records.” Reyes v. Freeberry, No. 02-1283-KAJ, 2005 WL 3560724, at *6 (D. Del. Dec. 29, 2005). Indeed, the Delaware Office of Attorney General has noted that the statute even prohibits disclosure of “completed internal affairs investigations statistical summaries.” Del. Op. Att’y Gen. 16-IB02, 2016 WL 1072888, at *2 (Jan. 14, 2016) (noting that the statute prohibits disclosure of “all records compiled as a result of any investigation subject to the provisions” the Delaware Law Enforcement Officers’ Bill of Rights (quoting Del. Code Ann. tit. § 9200(c)(12)) (emphasis added).
 Cal. Penal Code § 832.7. The statute designates as public all records relating to firearms discharge or serious use of force (whether substantiated or not), and all allegations of sexual assault or dishonesty (if substantiated).