Los Angeles Police Protective League v. City of Los Angeles

We are asked to decide whether Sergeant Robert Smith is entitled to arbitrate the decision of the Los Angeles Police Department to transfer him to a different assignment with the reduced pay applicable to that assignment. Appellant argues the issue is arbitrable because it constitutes a downgrade in pay. Respondents argue it is not because transfers are reviewable only by administrative appeal, not by arbitration, because the transfer and pay downgrade are inextricably intertwined under the civil service system applicable to the police department. (The parties have submitted unpublished appellate court decisions upon which neither they nor we are entitled to rely as precedent.) We conclude that Sergeant Smith is not entitled to arbitration and affirm the order of the trial court.

Factual and Procedural Summary

Sergeant Smith is a 25-year veteran of the Los Angeles Police Department (Department). In August 1999, he was transferred from the West Los Angeles Station to the Wilshire Station and assigned to less demanding duties than he had before. The change resulted in a downgrade of his pay classification from sergeant II to sergeant I. The reason for the transfer was…