DeCuir

Introduction

Defendants and appellants the County of Los Angeles, Ronald Maus, Frederick Leonhardt, and David Walters appeal from a judgment after jury trial in favor of plaintiff and respondent Emille V. DeCuir. The jury awarded plaintiff $380,000 in lost future wages based on plaintiff’s allegations that defendants’ examination process for the civil service position of district attorney investigator was unfair and resulted in his receiving a lower score than he deserved, thus precluding his being selected for the position. Defendants contend on appeal that plaintiff’s exclusive form of judicial review was a proceeding in mandamus rather than a jury trial, that defendants are immune from damages, and that plaintiff failed to establish causation as a matter of law. We agree with defendants’ contention that plaintiff was limited to bringing a mandamus proceeding to challenge defendants’ actions. We therefore reverse the judgment on that basis, without the necessity of addressing defendants’ remaining contentions.

Factual and Procedural Background

In March 1989, after submitting an application, plaintiff took the civil service examination for the position of investigator…