On September 5, 2007, the State of Washington published the first opinion holding that a police officer who lies should be terminated as a matter of public policy. In Kitsap County Deputy Sheriff’s Guild v. Kitsap County, the sheriff terminated Deputy LaFrance for untruthfulness and erratic behavior. An arbitrator agreed that LaFrance had repeatedly been untruthful but was not convinced that termination was the proper form of discipline; the arbitrator therefore ordered him returned to full duty. Eventually the case found its way to the appellate court, which concluded that the arbitration award was unenforceable as against public policy.¹ It relied primarily on the sheriff’s conclusion that LaFrance was not fit for duty due to Brady concerns about his ability to testify. In Brady v. Maryland, the U.S. Supreme Court ruled that a prosecutor must release information favorable to an accused upon request;² therefore, if LaFrance were to testify in a criminal proceeding, the prosecutor would be legally and ethically obligated to disclose his history of untruthfulness to defense counsel. “Put simply, LaFrance’s proven record of dishonesty prevents him from useful service as a law enforcement officer. To require his reinstatement to a position of great public trust in which he cannot possibly serve violates public policy.”³