After firing Towner, an investigator in the County’s District Attorney’s office, the County sought a writ of mandate to enjoin the County’s Civil Service Commission from reviewing the termination.  In support of its writ petition, the County publicly filed confidential reports of its investigation of Towner’s conduct, in violation of Gov. Code 832.7, part of the Police Officer’s Bill of Rights Act, which requires public entities to follow specific procedures before publicly disclosing peace officers’ confidential employment records.  Towner then sued the County for publicly disclosing those records.  The trial court erred in granting the County’s Anti-SLAPP motion.  While the County had made the disclosure in the course of litigation so that its speech ordinarily would have been protected under CCP 425.16, this disclosure fell within the exception for “illegal conduct” under Flatley v. Mauro (2006) 39 Cal.4th 299.  Gov. Code 832.7 made the disclosure illegal.  And, Gov. Code 1222 makes an public official’s willful omission to perform a duty enjoined by law a misdemeanor.  Here, the failure to follow the POBRA’s procedures before publicly disclosing Towner’s records was clearly willful in the sense of being an intentional act or omission.