People Ex Rel. Deputy Sheriffs' Ass'n v. County of Santa Clara

Plaintiffs appeal the trial court’s ruling that defendant County of Santa Clara (hereafter, County) could consolidate the offices of chief probation officer and director of the County’s department of corrections. Their main contention is that the offices are inherently incompatible and cannot be legally merged.

Facts

In 1987, in Santa Clara County Charter section 509, ratified by the voters on June 6, 1988, the County established a department of corrections (hereafter, Corrections) to run the County’s jails pursuant to Government Code section 23013. The board of supervisors (hereafter, board) transferred jurisdiction over the jails from the sheriff to a director of corrections (hereafter, director) who staffed the jails with “correctional officers” and “correctional deputies.” The former were hired and trained by the director; the latter originally had been hired and deputized by the sheriff. After the changeover, in addition to being members of Corrections, the correctional deputies remained members of the sheriff’s department with the contractual right to transfer into the sheriff’s department as openings arose. By June 1990, a substantial number had taken advantage…