“Personnel Information” and Foreseeable Admissibility: Doe v. Concord Police Department and the Scope of New Hampshire’s Exculpatory Evidence Schedule

I. Introduction

The Supreme Court of New Hampshire’s decision in Doe v. Concord Police Department & a., 2025 N.H. 48 (Nov. 19, 2025), clarifies two critical aspects of the State’s regime for cataloging police officer misconduct that may be relevant in criminal cases:

1. The meaning and breadth of “personnel information” under RSA 105:13-d (the statute establishing the Exculpatory Evidence Schedule, or EES), and
2. The proper interpretation of the “reasonably foreseeable case” standard for removing an officer’s name from the EES, as articulated in Doe v. New Hampshire Attorney General (Activity Logs), 176 N.H. 806, 2024 N.H. 50 (2024).

Jane Doe, a former Concord police officer, sought removal of her name from the EES, arguing that: (1) her misstatement was immaterial and did not constitute “misconduct” as defined in RSA chapter 106-L; (2) records of the misconduct had been removed from her “personnel file” under a settlement agreement; and (3) in any event, there was no reasonably foreseeable case in which information about the incident would be admissible, especially since she had left law enforcement more than a decade earlier.

The Supreme Court’s opinion, authored by Donovan, J., rejects all three arguments and, in doing so, sets out important interpretive rules that will shape how law enforcement agencies, prosecutors, defense counsel, and courts understand the scope and function of the EES going forward.

II. Summary of the Opinion

A. Factual Background

In 2013, while both the plaintiff and another officer were employed by the Concord Police Department, a fellow officer discovered that her firearm was missing from her assigned locker at the police station. Only one other locker was closed and locked, and that locker belonged to the plaintiff, who had recently been in the area and had left to transport a prisoner to a hospital.

A sergeant contacted the plaintiff at the hospital and confirmed that she was in possession of the other officer’s firearm. The plaintiff told the sergeant that she had realized, while still at the station, that she had forgotten her firearm and had asked another officer to retrieve it, suggesting the other officer must have taken the wrong weapon.

When she returned to the station, the plaintiff repeated this account to a sergeant and lieutenant. However, the plaintiff’s partner reported that the plaintiff did not realize she was missing her firearm until she arrived at the hospital. The officer whose firearm was missing then informed supervising officers that the plaintiff had lied about when she realized the firearm was missing.

An internal affairs investigation concluded that the plaintiff:

• lied to a colleague and supervisors regarding when she first realized she had forgotten her firearm,
• failed to answer truthfully during the internal investigation,
• falsely denied speaking to a lieutenant and sergeant about the incident, and
• gave inconsistent factual accounts to different supervisors.

The chief sustained these findings, terminated the plaintiff’s employment, and recommended her for inclusion on what was then commonly known as the “Laurie List,” now codified as the Exculpatory Evidence Schedule (EES) under RSA 105:13-d. The City’s Personnel Appeals Board (PAB) upheld the termination, again finding the plaintiff lacked credibility.

The plaintiff later sued the City in superior court, asserting gender discrimination and wrongful termination claims. The parties settled. As part of the settlement:

• Documents relating to the incident and the plaintiff’s termination were to be removed from her “permanent personnel files” and maintained in a separate investigative file by the Concord Police Department and Human Resources Department, and
• The police standards and training council would be notified that her departure was a “negotiated resignation.”

Years later, the plaintiff brought the present action against the City and the New Hampshire DOJ, seeking removal of her name from the EES.

B. Procedural Posture

The DOJ moved for summary judgment, and the City joined. The trial court (Tucker, J.) granted the motion, finding that:

• The plaintiff’s personnel information contained “potentially exculpatory evidence” within the meaning of RSA 105:13-d, and
• There remained a reasonably foreseeable scenario in which her sustained findings of untruthfulness could be admissible in a future criminal case.

The plaintiff’s motion for reconsideration was denied, and she appealed to the Supreme Court of New Hampshire.

C. Holdings

The Supreme Court affirmed the grant of summary judgment and clarified significant legal principles:

1. RSA chapter 106-L’s definition of “misconduct” is not controlling for EES determinations. The statute governing the EES is RSA 105:13-d, and it does not incorporate RSA 106-L’s specific definition of misconduct.
2. “Personnel information” under RSA 105:13-d is broader than “personnel file.” Even if documents are removed from an officer’s formal personnel file and placed in a separate “investigative” file pursuant to a settlement, they still constitute “personnel information” for purposes of the EES.
3. The “reasonably foreseeable case” standard focuses on the foreseeability of admissibility, not the likelihood that the officer will actually testify. Clarifying Doe (Activity Logs), the Court held that the key inquiry is whether, assuming a future case arises in which the officer testifies, it is reasonably foreseeable that the misconduct evidence would be admissible, especially for impeachment.
4. Sustained findings of untruthfulness are paradigmatic “potentially exculpatory evidence.” The plaintiff’s sustained dishonesty is reasonably capable of bearing on her credibility in any future case where she testifies, and therefore justifies continued inclusion on the EES, despite the passage of time and her retirement from law enforcement.

III. Detailed Analysis

A. Statutory Framework

1. RSA 105:13-b – Exculpatory Evidence in Police Personnel Files

RSA 105:13-b governs exculpatory evidence located in the “police personnel file of a police officer who is serving as a witness in any criminal case.” Historically, it has been tightly linked with the prosecutor’s constitutional duty under Brady v. Maryland and Giglio v. United States to disclose favorable or impeaching evidence to the defense.

In New Hampshire Center for Public Interest Journalism v. N.H. Department of Justice, 173 N.H. 648 (2020), the Court stressed that RSA 105:13-b is focused on information in the officer’s personnel file. That opinion expressly noted that the legislature could have written a broader statute covering “personnel information” generally, but did not.

2. RSA 105:13-d – Exculpatory Evidence Schedule (EES)

Following N.H. Center for Public Interest Journalism, the legislature enacted RSA 105:13-d, creating the Exculpatory Evidence Schedule:

“The [EES] shall consist of a list of all current or former law enforcement officers whose personnel information contain potentially exculpatory evidence.” RSA 105:13-d, I (emphasis added).

Thus, while RSA 105:13-b is framed in terms of “personnel file,” RSA 105:13-d deliberately uses the broader phrase “personnel information.” This linguistic shift is central to the Court’s analysis in Doe v. Concord Police Department.

3. RSA Chapter 106-L – Police Standards and Training Council

RSA chapter 106-L regulates the New Hampshire Police Standards and Training Council (PSTC) and includes:

• Definitions applicable “[i]n this chapter,” including “misconduct” (RSA 106-L:2),
• Certification standards for police officers (RSA 106-L:5, III–V), and
• Provisions for disciplinary hearings and sanctions on officer certification (RSA 106-L:5, XXV).

Under RSA 106-L:2, V, “misconduct” for PSTC purposes includes a “deliberate and material lie” in specified contexts, including internal investigations.

Crucially, RSA 106-L:22 acknowledges that the duty to disclose “potentially exculpatory materials” in criminal cases is governed by RSA 105:13-b, not by chapter 106-L itself. This underscores the separateness of the PSTC disciplinary regime from the EES/Brady-disclosure framework.

B. Precedents Cited and Their Influence

1. State v. Laurie, 139 N.H. 325 (1995)

Laurie is the foundational New Hampshire case that gave rise to the informal “Laurie List,” the precursor to the EES. In Laurie, the prosecution failed to disclose impeachment evidence concerning a police officer witness’s prior misconduct that bore directly on his credibility.

The Court held that:

• Due process requires disclosure of material impeachment evidence, and
• Where the State fails to reveal such evidence, a conviction may be reversed.

Laurie established the principle that credibility-related misconduct by law enforcement officers can be “exculpatory” in the constitutional sense, particularly when that officer is a key witness. In Doe v. Concord Police Department, the Court revisits Laurie to reinforce that evidence bearing on an officer’s honesty is inherently “reasonably capable of being material to guilt or to punishment” (see ¶24, citing Doe (Activity Logs) and Laurie).

2. N.H. Center for Public Interest Journalism v. N.H. Dep’t of Justice, 173 N.H. 648 (2020)

This case addressed public access to the then-confidential “Laurie List” and interpreted RSA 105:13-b. The Court emphasized:

• The statute’s focus on information maintained in a specific officer’s “personnel file,” and
• That the legislature had not extended the statute’s coverage to “personnel information” more generally.

In Doe v. Concord Police Department, the Court uses this prior interpretation as a springboard to contrast RSA 105:13-b with the newer RSA 105:13-d:

• RSA 105:13-b — narrowly focused on “personnel file.”
• RSA 105:13-d — deliberately broader, using “personnel information.”

By juxtaposing these statutes, the Court concludes that the legislature intentionally expanded the scope of EES-relevant material beyond what is physically stored in the personnel file, a conclusion that directly undercuts Doe’s reliance on the settlement-driven removal of documents from her official file.

3. Duchesne v. Hillsborough County Attorney, 167 N.H. 774 (2015)

In Duchesne, officers challenged their inclusion on a “Laurie List” where the adverse information concerned allegations of excessive use of force. The Court reasoned that:

• Even assuming the misconduct allegations were true, mere evidence of excessive force, without dishonest conduct such as lying or misrepresentation, is typically not admissible to attack an officer’s general credibility.
• Such evidence cannot be used simply to show the officer’s propensity to use excessive force in some later case.

Therefore, the Court held that the inadmissibility of such conduct for general impeachment purposes “has a strong bearing on the propriety of maintaining the officer’s name on” the list. The key point is that not all criticism-worthy conduct is relevant to credibility in a later case.

In Doe v. Concord Police Department, this reasoning is contrasted with the plaintiff’s conduct:

• In Duchesne, the underlying conduct was force-related, not directly about truthfulness.
• In the present case, the underlying conduct was sustained untruthfulness in an internal investigation and dealings with supervisors, which directly attacks the officer’s character for truthfulness.

Thus, where Duchesne suggested removal from (or non-inclusion on) a list was appropriate because the misconduct would not generally be admissible to impeach, Doe reaches the opposite conclusion because the misconduct is quintessential impeachment material.

4. Doe v. N.H. Attorney General (Activity Logs), 176 N.H. 806, 2024 N.H. 50 (2024)

Activity Logs is central to the present decision. There, the Court held that when deciding whether an officer’s name should be on the EES, decision-makers should consider:

• The age of the conduct,
• The materiality of the conduct to the officer’s general credibility, and
• Whether “there is no reasonably foreseeable case in which ‘potentially exculpatory evidence’ relating to an officer’s conduct would be admissible.”

However, Doe clarifies that Activity Logs has been misunderstood. The plaintiff argued that because, as a retired officer, it was extremely unlikely she would ever be called as a witness, her EES listing should be removed. The Court corrects this reading.

The clarified rule: The question is not how likely it is that the officer will testify in some future case, but rather whether, if such a case arises and the officer testifies, it is reasonably foreseeable that the misconduct evidence would be admissible. This is a subtle but important doctrinal refinement.

5. Doe v. Salem Police Dep’t (Off-duty Speeding), 177 N.H. 20, 2024 N.H. 54 (2024)

In Off-duty Speeding, the Court approved removal from the EES where:

• The misconduct was an off-duty speeding incident more than ten years old, and
• “Nothing in the complaint or accompanying documentation suggest[ed] that the plaintiff acted dishonestly or attempted to conceal his conduct.”

Comparing that decision with the present case, the Court emphasizes that conduct without dishonesty generally has far less impeachment value than conduct involving lying or concealment. Thus:

• Old, isolated, and non-deceptive misconduct (like dated off-duty speeding) can justify removal from the EES.
• Old but deception-based misconduct (like sustained findings of lying in an internal investigation) continues to have potent impeachment value and supports continued inclusion.

C. The Court’s Legal Reasoning

1. Inapplicability of RSA chapter 106-L’s “Misconduct” Definition

The plaintiff contended that her actions did not constitute “misconduct” under RSA 106-L:2, V because, in her view, her misstatement was immaterial to any policy violation. She argued that the precise moment when she realized she had forgotten her firearm (at the station vs. at the hospital) did not matter.

The Court rejects this argument on two levels:

1. Doctrinally: The definition of “misconduct” in RSA 106-L:2, V applies only “[i]n this chapter,” i.e., to PSTC certification and disciplinary proceedings. It does not govern EES determinations, which are governed by RSA 105:13-d. Nothing in RSA 105:13-d refers back to RSA 106-L, and RSA 106-L itself separates its disciplinary regime from the Brady/EES regime by pointing to RSA 105:13-b for exculpatory disclosure obligations. Thus, importing RSA 106-L’s definition is doctrinally incorrect.
2. Factually (even if RSA 106-L applied): In footnote 1, the Court explains that the timing of the plaintiff’s realization is far from immaterial. It is a “more egregious breach of policy” to transport a prisoner unarmed to a hospital than to discover the problem before leaving the station. Therefore, lying about when she discovered the missing firearm is “material” to both the underlying violation and the internal investigation.

This two-pronged analysis insulates the Court’s conclusion: even under the plaintiff’s preferred statutory framework, her argument would fail on the merits.

2. “Personnel Information” vs. “Personnel File” – The Effect of the Settlement Agreement

The plaintiff relied on the settlement’s requirement that the incident and termination documents be removed from her “permanent personnel files” and maintained only in a separate investigative file. She argued that because the “alleged misconduct is no longer in [her] official police personnel file,” her name should be removed from the EES.

The Court’s reasoning proceeds as follows:

1. Textual contrast with RSA 105:13-b: Citing N.H. Center for Public Interest Journalism, the Court recalls that RSA 105:13-b is focused on the “personnel file” and that had the legislature intended that statute to reach all “personnel information,” it would have said so.
2. Legislative expansion in RSA 105:13-d: When the legislature enacted RSA 105:13-d after N.H. Center for Public Interest Journalism, it deliberately referred to “personnel information,” not “personnel file.” This broader language demonstrates legislative intent to cover a wider universe of records relating to an officer, regardless of where those records are stored.
3. Functional perspective: The EES is described in Doe (Activity Logs) as “a tool to identify information about police officers . . . that is subject to possible disclosure.” From that vantage point, it would make little sense to allow the content of the EES to turn on the physical or administrative location of documents. Agencies could otherwise evade their obligations by simply relocating controversial materials out of the personnel file and into a separate archive.

Applied to the case at hand, the Court holds:

• Despite the settlement agreement, the incident and investigation records remain “personnel information,” and
• They are therefore within the ambit of RSA 105:13-d and properly support the plaintiff’s continued inclusion on the EES.

In effect, the Court makes clear that public employers cannot contract around the State’s EES framework by re-labeling or re-filing records. The legal character of the documents (as personnel-related) is not altered by their relocation.

3. Clarifying the “Reasonably Foreseeable Case” Standard

The plaintiff next argued that EES inclusion was now purposeless because she had not been a police officer for more than ten years and was retired. She read Doe (Activity Logs) to say that if there is “no reasonably foreseeable criminal case” in which the officer will be a witness, then EES inclusion is improper.

The Court rejects this reading and “take[s] this opportunity to clarify the standard” (¶21–22).

a. What Doe (Activity Logs) Actually Requires

Properly understood, the standard is:

• Decision-makers must consider the admissibility of the misconduct evidence in some hypothetical future case, not the statistical likelihood of such a case arising or of the officer being called as a witness.
• If, assuming a future case arises in which the officer testifies, it is not reasonably foreseeable that the prior misconduct would be admissible, then inclusion on the EES would be inappropriate.
• Conversely, if the misconduct would be reasonably foreseeable as admissible (for example, as impeachment evidence under N.H. R. Evid. 608(b)), then inclusion is appropriate, regardless of how often the officer is likely to testify.

The Court explicitly disclaims any requirement that courts assess the likelihood of the officer’s future testimony:

“Contrary to the plaintiff’s interpretation of Doe (Activity Logs), this standard does not require courts to assess the likelihood that a criminal case would be brought at which the officer would be called as a witness.” (¶22)

b. Application to the Plaintiff’s Misconduct

Under this clarified framework, the Court reasons:

• The plaintiff has sustained findings of untruthfulness by her department and by the City’s Personnel Appeals Board.
• Such findings are classic impeachment fodder: if she were to testify in a future criminal case, opposing counsel could seek to cross-examine her on these acts as “acts probative of [her] character for truthfulness or untruthfulness” under N.H. R. Evid. 608(b).
• Thus, it is reasonably foreseeable that this misconduct would be admissible to impeach her credibility in a future case where she testifies.

The Court therefore concludes that there is not “no reasonably foreseeable case” in which the misconduct would be admissible; on the contrary, the continued EES listing is justified because her prior dishonesty is precisely the kind of information the EES is designed to capture.

4. Summary Judgment and the Trial Court’s Reasoning

The Court applies the usual summary judgment standard: viewing the evidence in the light most favorable to the plaintiff, are there any genuine issues of material fact, and is the moving party entitled to judgment as a matter of law?

Here:

• The underlying facts of the misconduct and its documentation are not genuinely disputed; they have been sustained through multiple proceedings.
• The questions are legal: which statutes govern, what “personnel information” means, and how the Activity Logs foreseeability standard applies.

The Supreme Court notes that, although the trial court ruled before Activity Logs was decided, its reasoning was consistent with the later-articulated standard. The trial court:

• Considered the age of the misconduct,
• Considered its relevance to general credibility, and
• Recognized that “depending on the case,” the findings of untruthfulness might be admitted to attack the plaintiff’s credibility.

The Supreme Court therefore affirms the trial court’s legal conclusions and the grant of summary judgment.

IV. Complex Concepts Simplified

A. The Exculpatory Evidence Schedule (EES) and the “Laurie List”

The “Laurie List” was an informal label for lists prosecutors maintained of police officers with credibility-related problems, created in response to State v. Laurie. The EES, codified at RSA 105:13-d, is the formal, statutory version of that list.

The EES is:

• Maintained by the New Hampshire Department of Justice,
• Intended to catalog officers whose personnel information contains “potentially exculpatory evidence,” and
• Used as a tool by prosecutors to identify information that may need to be disclosed to criminal defendants under constitutional and statutory obligations.

B. “Potentially Exculpatory Evidence”

“Exculpatory evidence” broadly includes:

• Evidence that tends to show the defendant did not commit the crime (direct exculpation), and
• Evidence that tends to impeach (undermine) the credibility of prosecution witnesses, especially law enforcement officers (impeachment evidence).

“Potentially” exculpatory evidence is evidence that may be exculpatory depending on how a future case develops. Evidence of an officer’s dishonesty is a classic example: if that officer is later a key witness in a criminal trial, the defendant may use such evidence to argue the officer is untrustworthy, which can affect whether the jury believes the officer’s testimony.

C. “Personnel File” vs. “Personnel Information”

• Personnel file – The official employment file an employer keeps on an employee, generally containing documents like hiring forms, evaluations, discipline notices, and termination papers.
• Personnel information – A broader category that includes all information related to the employee’s work and performance, whether or not it is physically stored in the formal personnel file.

In this case, the Court holds that “personnel information” under RSA 105:13-d includes investigative files kept separately from the personnel file. Thus, a settlement agreement that moves a document from the personnel file to another location does not change its status as “personnel information.”

D. Summary Judgment

Summary judgment is a procedural device to resolve cases where no material facts are genuinely disputed and the case can be decided purely as a matter of law. The moving party (here, the DOJ and the City) must show:

1. There are no genuine disputes of material fact, and
2. They are entitled to judgment under the applicable legal standards.

Courts assume disputed facts in favor of the non-moving party, but if only legal issues remain (as in statutory interpretation and application to undisputed misconduct), summary judgment can be appropriate.

E. Impeachment Under N.H. R. Evid. 608(b)

Rule 608(b) of the New Hampshire Rules of Evidence allows a party, on cross-examination, to inquire into specific instances of a witness’s conduct “if they are probative of the character for truthfulness or untruthfulness of . . . the witness.”

Applied here:

• The plaintiff has sustained findings of lying and giving inconsistent statements during an investigation.
• Those acts are clearly probative of her character for truthfulness.
• Therefore, in a future case where she testifies, a court might allow cross-examination about these acts under Rule 608(b).

That realistic possibility of admissibility is why the Court finds that it remains reasonably foreseeable that her misconduct could be used in a future criminal case, justifying continued EES inclusion.

F. “Reasonably Foreseeable Case” and Admissibility

The “reasonably foreseeable case” concept is subtle:

• It does not ask how likely it is that the officer will be called to testify.
• It asks, instead: If a future case arises where the officer testifies, is it reasonably foreseeable that the past misconduct would be admissible (e.g., as impeachment)?

Only when it is not reasonably foreseeable that the misconduct would be admissible even if the officer testifies (e.g., old, non-credibility-related conduct barred by evidentiary rules) should EES removal be seriously considered.

V. Impact and Implications

A. For Police Officers and Their Counsel

1. Settlement Agreements Cannot “Erase” EES-Relevant Misconduct.

   Officers (and unions) should understand that negotiating to remove documents from a formal personnel file will not, by itself, remove or prevent EES listing. Any investigative material concerning the officer that is retained by the employer remains “personnel information” and can support EES inclusion.

2. Nature of the Misconduct Matters More Than Its Age Alone.

   The Court’s comparison of this case with Duchesne and Off-duty Speeding underscores that dishonesty is treated very differently from non-deceptive misconduct. Sustained findings of untruthfulness will be presumed to have ongoing impeachment value, often defeating removal requests even years later.

3. Retirement Does Not Automatically Wipe the Slate Clean.

   The plaintiff’s retirement and long absence from law enforcement did not carry significant weight. Officers should not expect EES removal simply because they are unlikely to testify. The focus is whether the misconduct is admissible if they do.

B. For Municipalities and Law Enforcement Agencies

1. Record-Keeping Strategies Cannot Evade EES Obligations.

   Agencies cannot avoid EES consequences by relocating or re-labeling records as “investigative” rather than “personnel.” All records relating to the officer’s conduct remain “personnel information” under RSA 105:13-d.

2. Need for Careful Assessment Before EES Recommendations.

   Agencies must distinguish between:

   • Credibility-focused conduct (e.g., lying, falsifying reports, misleading supervisors), which almost always supports EES inclusion, and
   • Non-credibility conduct (e.g., certain uses of force or off-duty misbehavior without deception), which may not.

   The Court’s decision provides a clearer blueprint for agencies to evaluate which cases warrant EES recommendations.

C. For the Department of Justice and Prosecutors

1. Confirmation of Broad “Personnel Information” Mandate.

   The DOJ’s interpretation of “personnel information” as extending beyond the formal personnel file is validated. Prosecutors should ensure that EES screening processes capture all relevant investigative materials, not just those in human resources files.

2. Sharper Focus on Admissibility in Future Cases.

   Prosecutors should adopt the clarified Activity Logs standard: ask whether the misconduct would likely be admissible for impeachment, assuming the officer testifies. This places the emphasis on evidentiary rules and types of misconduct rather than on career stages or subjective predictions of future litigation.

D. For Criminal Defense Counsel

Defense attorneys benefit from the Court’s reaffirmation that:

• The EES must retain officers whose prior dishonesty remains admissible as impeachment, and
• Attempts to “hide” misconduct by moving documents out of personnel files do not eliminate their status as EES-relevant.

This decision strengthens defendants’ ability to argue that prosecutors must disclose impeachment evidence about officers who appear on the EES, particularly in cases where officer testimony is pivotal.

E. For the Courts

Trial courts now have a more refined framework for dealing with EES appeals or related challenges:

• They must focus on whether the misconduct is credibility-related and reasonably foreseeable as admissible in a future case, not merely on how long ago it occurred or whether the officer is currently active.
• They should consider the type of misconduct (truthfulness vs. non-truthfulness) as a central factor, along with time passed and any evidence of rehabilitation, when appropriate.

VI. Conclusion

Doe v. Concord Police Department & a., 2025 N.H. 48, is a significant clarification of New Hampshire’s Exculpatory Evidence Schedule jurisprudence. The Court firmly separates the EES framework under RSA 105:13-d from the Police Standards and Training Council’s disciplinary regime under RSA chapter 106-L, rejecting attempts to import the latter’s “misconduct” definition into EES disputes.

By construing “personnel information” to include records maintained outside an officer’s formal personnel file, the Court closes a potential loophole that could have allowed agencies and officers to contract around EES obligations via settlement agreements and administrative re-filing. The decision also refines the “reasonably foreseeable case” standard from Doe (Activity Logs), emphasizing that the key inquiry is the foreseeability of admissibility of the misconduct in a hypothetical future case where the officer testifies, not the statistical likelihood that such a case will arise.

Placed in context with Laurie, Duchesne, Activity Logs, and Off-duty Speeding, the opinion fortifies a principled distinction between:

• Misconduct that directly implicates an officer’s honesty and thus has enduring impeachment value, and
• Misconduct that, while serious, does not ordinarily bear on general credibility and may not justify EES listing, especially as time passes.

The decision thus reaffirms that New Hampshire’s EES is not a general disciplinary database, but a targeted tool to ensure courts and defendants are alerted to information that may materially affect the credibility of law enforcement witnesses and, by extension, the fairness of criminal trials.