In the Pitchess v. Davis case of 1974, the U.S. Supreme Court ruled on a dispute involving access to police records for defense purposes in criminal trials. The defendant, Davis, was charged with battery against a police officer and sought access to complaints filed against the officers involved in his arrest as part of his defense strategy. He argued that these records could potentially reveal instances of excessive force or dishonesty by these officers which would be relevant to his case. Sheriff Pitchess denied this request citing confidentiality concerns. The California Supreme Court sided with Davis stating that defendants have a right to discover such information if it is material to their defense under due process rights guaranteed by the Fourteenth Amendment; however, they also noted that trial courts should review such requests carefully balancing privacy interests and public safety considerations. When appealed at federal level, U.S Supreme court vacated judgement and remanded back for further proceedings consistent with its opinion.

In the dissenting opinion for Pitchess v. Davis, Justice William O. Douglas argued that the majority's decision was a violation of due process rights under the Fourteenth Amendment. He contended that an accused person has a constitutional right to access evidence necessary for their defense, including police records which could potentially reveal patterns of misconduct or bias on behalf of arresting officers. In this case, he believed that denying such access would result in an unfair trial and thus violate due process rights as guaranteed by the Constitution. Furthermore, he expressed concern about potential abuses within law enforcement agencies if they were allowed to withhold information from defendants without judicial oversight or review.