Date of Offense
Official Statement
The article from The Bulletin dated May 30, 2025, reports on disciplinary actions involving Deschutes County Sheriff's Deputy Ryan McNee. An internal investigation concluded that Deputy McNee engaged in multiple forms of misconduct during a March 3, 2024, incident, including falsifying his report, using excessive force, failing to activate his body-worn camera, and neglecting to announce the release of his police dog. However, upon assuming office on January 1, 2025, Sheriff Kent Van der Kamp overturned the finding related to report falsification and omitted the sustained use-of-force violations from the disciplinary record. Consequently, Deputy McNee received a one-year probation, removal from the K-9 program, mandatory use-of-force training, and a deduction of two days' pay.
In the context of Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972), prosecutors are constitutionally obligated to disclose evidence favorable to the defense, including information that could impeach the credibility of a government witness. This encompasses prior acts of dishonesty or misconduct by law enforcement officers . Even if internal disciplinary findings are altered or overturned, the underlying conduct may still be considered material for impeachment purposes. Therefore, the initial findings regarding Deputy McNee's conduct could necessitate disclosure under Brady and Giglio obligations, as they bear on his credibility as a witness.
Moreover, the decision by Sheriff Van der Kamp to modify the disciplinary findings raises concerns about transparency and the potential impact on the integrity of prosecutions involving Deputy McNee.
