Irvin
Irvin v. City of Los Angeles CA2/2
Opinion
Opinion
BACKGROUND
I. The Complaint
Irvin, a Los Angeles Police Department detective, filed a complaint asserting a single cause of action against the City for retaliation in violation of section 1102.5. Irvin alleged that her commanding officer “falsif[ied] . . . time-sheets . . . by claiming hours worked while conducting personal errands.” Specifically, the commanding officer “would routinely go home to cook and/or take care of her ‘family’ of feral cats” and would also require other officers to care for the cats during work hours. Irvin alleged that when she reported this “unlawful conduct” she was subjected to retaliation, including receiving numerous write-ups and being transferred to another division.
II. Summary Judgment
A. The City’s motion The City moved for summary judgment, contending that “the burden[-]shifting analysis of McDonnell Douglas” applied. The City explained that framework as follows: “[Irvin] carries the initial burden of establishing a prima facie case by showing that: (1) she engaged in protected activity; (2) the City subjected her to an adverse employment action; and (3) there exists a causal link between the protected activity and the adverse employment…