January 30, 2026
Court of Appeal, Third Appellate District (Sacramento)
The Rule of Brown v. Department of Motor Vehicles is that the Department of Motor Vehicles is not required to disclose the identity of a third-party reporter who initiates a driver reexamination proceeding, under circumstances where the reporter's form merely initiates the process but is not relied upon for the ultimate license suspension decision, the driver receives notice and hearing opportunities, and disclosure of the reporter's identity would compromise road safety by deterring future reports.