Sacramento County Deputy Sheriffs' Ass'n v. County of Sacramento

At the primary election on June 2, 1998, the voters of Sacramento County approved Measure D and Measure E, both of which dealt with the arbitration of employment disputes between the County of Sacramento and nonsupervisory law enforcement representatives. Measure D passed by 58 percent of the vote, while Measure E passed by 53 percent of the vote.

The difference between the initiatives is that Measure D provides that a decision of the arbitration board is final without need for approval by the board of supervisors or the electorate, whereas Measure E provides that the results of arbitration concerning certain contract provisions are binding only if approved by a majority of the votes cast in a county wide election in which the question of approval or disapproval is presented to the voters.

The Sacramento County Deputy Sheriffs’ Association (the Association), brought a declaratory relief action against the County of Sacramento (the County), contending that Measure E is ineffective because Measure D, approved by the voters at the same election, conflicts with Measure E and received a greater majority of the votes cast. The trial court granted judgment on the pleadings,…