Los Angeles Police Protective League v. City of Los Angeles

In this case we hold that the Public Safety Officers Procedural Bill of Rights Act (POBRA) (Gov. Code, § 3300 et seq.) does not afford officers the right to an administrative appeal of a transfer of assignment, which does not affect compensation or other specified rights, solely because the transfer may lead to negative employment consequences, or upon the officer’s belief to that effect. Instead, as the statute specifically requires, the transfer must be “for purposes of punishment.”

Appellants Los Angeles Police Protective League (League), Won Chu, and Felicia Hall appeal from a judgment denying their petition for writ of mandate and request for declaratory relief. Appellants Hall and Chu are public safety officers employed by respondent City of Los Angeles (City) and represented by the League. Appellants argue that the POBRA and the memorandum of understanding (MOU) between the City and the League entitle Chu and Hall to an administrative appeal of their involuntary transfers. We disagree and affirm the judgment.

FACTUAL AND PROCEDURAL SUMMARY

Hall was hired as a peace officer for the Los Angeles Police Department (LAPD) in 1985 and was promoted to lieutenant in…