The limitation of Evidence Code section 1045, subdivision (b)(1) precluding discovery of citizen complaints against a police officer which are more than five-years old did not violate federal or state constitutional guarantees of due process. Here the complaint was failure to report another officer’s improper use of mace, and was not material evidence where the defense may have been that witnesses were coached, and there was a more recently disclosed incident of failure to report a fellow officer’s misconduct.