Crawford

This appeal concerns application of the one-year statute of limitations contained in the Public Safety Officers Procedural Bill of Rights Act (Gov. Code, § 3300 et seq.). James Crawford was a detective in the Los Angeles Police Department (Department). Having been accused of nine counts of misconduct, Crawford’s employment was terminated after an administrative hearing and an adverse decision by the Department’s Board of Rights, which found him guilty of six counts of misconduct. Crawford brought a petition for peremptory writ of mandate under Code of Civil Procedure section 1094.5 against the City of Los Angeles and the chief of police (collectively the City), challenging the guilty findings and seeking reinstatement and backpay. The trial court granted the petition in part, finding Crawford could not be punished for five of the six acts of misconduct because the City did not complete its investigation of wrongdoing and notify Crawford within a year, as required by POBRA (§ 3304, subd. (d)). The court did not have occasion to consider Crawford’s claim that the Department’s misconduct findings were not supported by the administrative record.

In its timely appeal, the…