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Case 2:16-cv-03462 Document 1 Filed 05/19/16 Page 1 of 11 Page ID #:1

1 Stephen H. Silver, Bar No. 038241


shsilver@shslaborlaw.com
2 Jacob Kalinski, Bar No. 233709
jkalinski@shslaborlaw.com
3 SILVER, HADDEN, SILVER & LEVINE
1428 Second Street
4 Santa Monica, CA 90401
Telephone:
310.393.1486
5 Facsimile:
310.395.5801
6 Gregg McLean Adam, Bar No. 203436
gregg@majlabor.com
7 Jennifer S. Stoughton, Bar No. 238309
jennifer@majlabor.com
8 MESSING ADAM & JASMINE LLP
235 Montgomery Street, Suite 828
9 San Francisco, California 94104
Telephone:
415.266.1800
10 Facsimile:
415.266.1128
11 Attorneys for Plaintiff LOS ANGELES POLICE
PROTECTIVE LEAGUE
12
13

UNITED STATES DISTRICT COURT

14

CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

15
16 LOS ANGELES POLICE PROTECTIVE
LEAGUE,
17
Plaintiff,
18
v.
19
CITY OF LOS ANGELES, a municipal
20 corporation; and CHARLES BECK, in his
official capacity as Chief of Police for the City
21 of Los Angeles,
22

Case No.
COMPLAINT FOR DAMAGES, INJUNCTIVE
RELIEF AND DECLARATORY RELIEF FOR:
(1) VIOLATION OF THE CIVIL RIGHTS
ACT, 42 U.S.C. 1983
(2) VIOLATION OF THE 14TH AMENDMENT
(3) VIOLATION OF ARTICLE I, SECTION 15
OF THE CALIFORNIA CONSTITUTION

Defendants.
(4) VIOLATION OF CALIFORNIA CIVIL
CODE SECTION 52.1

23
24

(5) DECLARATORY RELIEF, 28 U.S.C.


2201

25
26

Plaintiff Los Angeles Police Protective League (Plaintiff or the League) alleges as

27 follows:
28

COMPLAINT

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1
2

I.
1.

INTRODUCTION

The League represents all peace officer members of the Los Angeles Police

3 Department (the LAPD), as that term is defined by California Penal Code section 830.1, in the
4 ranks of lieutenant and below (collectively police officers). These police officers are employed
5 by Defendant City of Los Angeles (the City), and they are under the command of the Chief of
6 Police, Defendant Charles Beck (the Chief of Police or the Chief) (collectively, with the City,
7 Defendants).
8

2.

The City and the Chief are bound by the Los Angeles City Charter (the Charter).

9 The Charter grants the City control over municipal affairs and imposes restrictions and
10 limitations upon the City. (Cal. Const. art XI.)
11

3.

Section 1070(a) of the Charter declares that LAPD officers in the City have a

12 substantial property right in their employment, which shall not be deprived arbitrarily or
13 summarily, nor other than as provided in [Section 1070].

In other words, LAPD officers

14 represented by the League are considered permanent civil service as that term is used in the Citys
15 Civil Service laws. California courts have recognized that those interests give rise to property
16 interests protected by due process. (See Cooper v. City of Los Angeles (July 16, 2001, B142714,
17 2nd Dist., Div, 7; Los Angeles Police Protective League v. City of Los Angeles (2002) 102
18 Cal.App.4th 85.)
19

4.

The due process clauses of the Fourteenth Amendment to the United States

20 Constitution and the California Constitution require the City to provide adequate procedural
21 safeguards before infringing upon LAPD officers employment-related property interests by firing
22 or suspending them.
23

5.

Among the procedural safeguards required by both due process clauses is that the

24 ultimate decision-maker(s) in disciplinary proceedings against LAPD officers must be impartial and
25 independent.
26

6.

The Charter nominally complies with due process requirements by prohibiting

27 Defendants from firing LAPD officers until they receive a full, fair and impartial hearing (Charter
28
-2COMPLAINT

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1 section 1070(a)) from a three-person panel, called a Board of Rights. A Board of Rights has the
2 sole authority to impose suspensions of greater than twenty-two days.
3

7.

The Board of Rights hears evidence against police officers, decides whether officers

4 committed misconduct, and determines the punishment for officers found guilty of misconduct.
5

8.

As presently constituted under the Charter, a Board of Rights is not a neutral and

6 independent decision-maker as due process demand. At the front end, the Chief submits the charges
7 and his recommendation to the Board of Rights. At the back end, two of the three members of a
8 Board of Rights must be high-ranking LAPD officers (i.e., captains and above), who report, through
9 their chain of command, to the Chief of Police.
10

9.

The high-ranking officers on a Board of Rights owe their positions and possible

11 promotion to the Chief. On its face this presents a structural conflict, with department Board of
12 Rights members under inherent pressure to find officers prosecuted under the Chiefs authority
13 guilty, and to impose the Chiefs recommended punishment. And in practice, as further alleged
14 below, the Chief of Polices influence has compromised and corrupted Board of Rights procedures
15 such as to deny Plaintiffs members their civil rights, including to due process.
16
17

II.
10.

THE PARTIES

Plaintiff the League is an employee organization, as defined in the California

18 Government Code sections 3500 et seq., and the exclusive representative of LAPD officers below
19 the rank of lieutenant, concerning the terms and conditions of their employment, including
20 disciplinary procedures. Plaintiff has associational standing to assert the constitutional and statutory
21 claims of its members.
22

11.

Defendant City is a charter city organized and existing under the laws of the State of

23 California. The City is located within the Central District of California.


24

12.

Defendant Charles Beck is the Chief of Police for the City, charged with the

25 supervision, administration, and management of the LAPD and its officers. On information and
26 belief, the Chief resides within the Central District of California. He is sued solely in his official
27 capacity.
28
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1
2

III.
13.

JURISDICTION AND VENUE

The League asserts claims arising under the laws and Constitution of the United

3 States, including the Civil Rights Act, 42 U.S.C. 1983, the Fourteenth Amendment, and the
4 Declaratory Judgment Act, 28 U.S.C. 2201which gives this Court jurisdiction pursuant to 28
5 U.S.C. 1331
6

14.

This Court has personal jurisdiction over the City because it is incorporated and

7 located within the State of California.


8

15.

This Court has personal jurisdiction over the Chief because he is domiciled within

9 the State of California.


10

16.

Venue for this action properly lies in this district pursuant to 28 U.S.C. 1391

11 because all of the Parties reside within this judicial district, and the events or omissions giving rise
12 to the claims occurred within this judicial district.
13
14

IV.
17.

FACTUAL ALLEGATIONS

The League has the right and responsibility to diligently protect the rights of all

15 LAPD officers up to the rank of lieutenant.


16

18.

Police officers accused of misconduct are entitled to several safeguards to protect

17 them against punishments that might be imposed in response to a meritless accusations.


18

19.

Among these protections, the Los Angeles City Charter specifies that no officer may

19 be fired, or suspended for more than twenty-two days, unless the officers case has first been heard
20 by a three-person Board of Rights. Every Board of Rights is specially constituted to hear the charges
21 brought against the officer, and each officer facing disciplinary proceedings is entitled to an
22 independent three-person panel.
23

20.

Under the Charter, a Board of Rights is supposed to independently determine

24 whether the officer engaged in misconduct. It is also supposed to determine the penalty for an
25 officers misconduct.
26

21.

The Chief does not have the authority to countermand a Board of Rights finding that

27 an officer engaged or did not engage in misconduct. Nor does the Chief have the power to increase
28 the penalty imposed by a Board of Rights. The Chiefs sole remaining power, once a Board of
-4COMPLAINT

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1 Rights makes a determination, is to reduce a penalty in the unlikely event that a Board of Rights
2 imposes a punishment greater than that recommended by the Chief.
3

22.

The Charter dictates, in Section 1070(h), that a Board of Rights shall be composed

4 of two officers of the rank of captain or above and an individual who is not a member of the
5 department (the civilian member). It is this provision that Plaintiff alleges violates its members
6 due process rights.
7

23.

Out of more than 9,000 officers in the LAPD, approximately 100 officers are of

8 sufficient rank, i.e., captains or above, to sit on a Board of Rights (the Board-Eligible Officers).
9 Different Boards of Rights have different compositions, but they all draw their non-civilian
10 members from the same limited pool of Board-Eligible Officers.
11

24.

By reason of their positions, managerial responsibilities and obligations to the Chief

12 of Policewho is their commanding officerthese Board-Eligible Officers have regular contact


13 with the Chief of Police and other high-ranking members of his command staff. The Chief makes
14 all promotions to the rank of captain or above, and he has ultimate control over future assignments,
15 responsibilities, and promotions.
16

25.

By design, Board-Eligible Officers owe their present positions and future prospects

17 to the Chief. Consequently, the two captains or above requirement of Section 1070(h) of the City
18 Charter inexorably leads to disciplinary proceedings against police officers accused of misconduct
19 which are not fair and impartial because two-thirds of the Board of Rights are controlled by and owe
20 allegiance to a Chief of Police whose is proposing the disciplinary action under review.
21

26.

The Board of Rights only hears complaints against an officer if the Chief has already

22 concluded that an officer is guilty of the allegations against him. (L.A. Charter 1070(a).) Once
23 the Board of Rights convenes, the Chief remains intimately involved in the proceedings: he
24 supervises the officers who present evidence (who are effectively the prosecution) against officers
25 appearing before a Board of Rights. The Chief also recommends punishments to the Board of
26 Rights.
27
28
-5COMPLAINT

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27.

Accordingly, when a Board of Rights gathers to hear the evidence against an officer,

2 the two Board-Eligible Officers know that the Chief believes that the officer is guilty of misconduct
3 and significant punishmentusually terminationshould be imposed.
4

28.

In almost all cases, a Board of Rights also knows that the Chief has asked for a

5 suspension of at least twenty-two days. In practice, the Chief rarely proposes punishment greater
6 than a twenty-two day suspension but short of termination, so Board of Rights members typically
7 know that the Chief seeks the termination of almost every officer appearing before a Board of
8 Rights.
9

29.

The inherent pressure built into the Board of Rights system for Board-Eligible

10 Officers to find an officer guilty of misconductand to impose a specific punishment, which is


11 almost always terminationinfringes upon a police officers due process right to a neutral decision12 maker in disciplinary proceedings which could end his or her career.
13

30.

The concern that the neutrality of the Board of Rights process is severely

14 compromised is not theoretical. Several captains have alleged that they: were pressured to convict
15 officers sent to a Board of Rights; suffered retaliation after disagreeing with the Chief during Board
16 of Rights proceedings; and/or heard other Board-Eligible Officers indicate their intent to find an
17 officer guilty simply because the Chief wanted them to do so.
18

31.

These extraordinary allegation by captains have appeared in four separate

19 whistleblower and retaliation actions against the City and the Chief. See Whittingham v. City of Los
20 Angeles, Case No. BC542732, Superior Court for the County of Los Angeles (filed April 14, 2014);
21 Ruiz v. City of Los Angeles, Case No. BC554102, Superior Court for the County of Los Angeles
22 (filed August 8, 2014); Carranza v. City of Los Angeles, Case No. BC561557, Superior Court for
23 the County of Los Angeles (filed October 22, 2014); Justice v. City of Los Angeles, Case No.
24 BC581567, Superior Court for the County of Los Angeles (filed May 13, 2015) (attached hereto as
25 Exhibits 1 4, respectively).
26

32.

Among other things, the captains alleged in their complaints:

27
28
-6COMPLAINT

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(a)

that one of the things Chief Beck looks at when deciding to upgrade captains is their

findings during a [Board of Rights], (Ex. 1 at 11);

(b)

the Chief of Police Charlie Beck [was] disappointed in the decision not to

terminate, and then told that he would be receiving training . . . on handling

Boards, (Exhibit 2 at 18);

(c)

a Board of Rights, we expect termination, (Exhibit 3 at 12); and

that shortly after ruling against the Chief, one was cautioned by a superior

that after rejecting the Chiefs request to terminate an officer, one was told

that one was told on behalf of Chief Beck that when we send someone to

10

(d)

11

Rights] to be reassigned to the hearing officers division as punishment, (Exhibit 4

12

at 15).

13

33.

that it is common practice to send officers that are acquitted in a [Board of

Far from the fair and impartial process intended by Charter section 1070(a) and

14 demanded by due process, an inherent structural conflict of interest in the Board of Rights
15 proceedings is created by Charter section (h), on its face and in practice, and the two Board-Eligible
16 Officers who sit on a Board of Rights cannot reasonably act in a fair and impartial capacity. As a
17 result, police officers accused of misconduct are deprived of the neutral decision-makers to which
18 they are entitled under due process jurisprudence.
19

34.

The Charter provisions mandating the use of these two Board-Eligible Officers,

20 found in Section 1070(h) of the Charter, must therefore be found unconstitutional.1


21

FIRST CAUSE OF ACTION

22

Violation of the Civil Rights Act, 42 U.S.C. 1983

23

35.

The League repeats and realleges each and every allegation in paragraphs 1 through

24 34 as if fully set forth herein.


25
26
1

If any section or subsection of the Charter is for any reason held to be unconstitutional
27 or otherwise invalid, that decision shall not affect the validity of the remaining portions of this
28 Charter. L.A. Charter 107. Thus, while Section 1070(h) is unconstitutional, the remaining
provisions of Section 1070 may remain unchanged.
-7COMPLAINT

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36.

Pursuant to Section 1070 of the Los Angeles City Charter, disciplinary proceedings

2 against LAPD officers are overseen by a Board of Rights whenever those proceedings might lead
3 to either termination or a suspension exceeding twenty-two days.
4

37.

Section 1070(h) of the Charter mandates that any such Board of Rights be comprised

5 of individuals who, by virtue of their positions within the LAPD, are inherently influenced by the
6 Chief of Police and cannot act as neutral and independent decision-makers. Acting under color or
7 law, Defendants enforce and uphold Section 1070(h) of the Charter in a manner which violates
8 Plaintiffs members civil rights, including to due process. Section 1070(h) of the Charter therefore
9 violates the Fourteenth Amendment Due Process rights of LAPD officers.
10

38.

Without appropriate relief, LAPD officers will continue to suffer adverse

11 employment decisions following unconstitutional hearings.


12

39.

As a result of the foregoing, the League is entitled to injunctive relief under 42 U.S.C.

13 1983, as described below.


14

WHEREFORE, plaintiff prays for relief, as hereinafter set forth.

15

SECOND CAUSE OF ACTION

16

Violation of the Fourteenth Amendments Due Process Clause

17

40.

The League repeats and realleges each and every allegation in paragraphs 1 through

18 39 as if fully set forth herein.


19

41.

Pursuant to Section 1070 of the Los Angeles City Charter, disciplinary proceedings

20 against LAPD officers are overseen by a Board of Rights whenever those proceedings might lead
21 to either termination or a suspension exceeding twenty-two days.
22

42.

Section 1070(h) of the Charter mandates that any such Board of Rights be comprised

23 of individuals who, by virtue of their positions within the LAPD, are inherently influenced by the
24 Chief of Police and cannot act as neutral and independent decision-makers. Section 1070(h) of the
25 Charter therefore violates the Fourteenth Amendment Due Process rights of LAPD officers.
26

43.

Nevertheless, Defendants enforce and uphold Section 1070(h) of the Charter.

27

44.

Without appropriate relief, LAPD officers will continue to suffer adverse

28 employment decisions following unconstitutional hearings.


-8COMPLAINT

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45.

As a result of the foregoing, the League is entitled to injunctive relief under the

2 Fourteenth Amendment.
3

WHEREFORE, plaintiff prays for relief, as hereinafter set forth.

THIRD CAUSE OF ACTION

Violation of the article 1, section 15 of the California Constitution (due process)

46.

The League repeats and realleges each and every allegation in paragraphs 1 through

7 45 as if fully set forth herein.


8

47.

Based on the conduct alleged in this complaint, Defendants acted under color of law

9 to deprive Plaintiffs members of certain constitutionally-protected rights including, but not limited
10 to, the right to procedural due process under article 1, section 15 of the California Constitution by
11 providing disciplinary procedures under Section 1070 of the Los Angeles City Charter that were not
12 fair and impartial.
13

48.

Without appropriate relief, LAPD officers will continue to suffer adverse

14 employment decisions following unconstitutional hearings.


15

49.

As a result of the foregoing, the League is entitled to injunctive relief to protect

16 LAPD officers rights under article 1, section 15 of the California Constitution.


17

WHEREFORE, plaintiff prays for relief, as hereinafter set forth.

18

FOURTH CAUSE OF ACTION

19
20

Violation of California Civil Code section 52.1


50.

The League repeats and realleges each and every allegation in paragraphs 1 through

21 49 as if fully set forth herein.


22

51.

Based on the conduct alleged in this complaint, Defendants violated California Civil

23 Code Section 52.1, in that they interfered, including through threats, intimidation or coercion, with
24 LAPD officers exercise of their civil rights, as enumerated herein, through violating their right to
25 a fair and impartial disciplinary proceeding for determination of their property interests.
26

52.

As a direct and proximate result of Defendants violation of Civil Code Section 52.1,

27 LAPD officers suffered violation of their constitutional rights, and suffered damages as set forth
28 herein.
-9COMPLAINT

Case 2:16-cv-03462 Document 1 Filed 05/19/16 Page 10 of 11 Page ID #:10

53.

Plaintiff is entitled to injunctive relief and an award of their reasonable attorney's

2 fees pursuant to Civil Code Section 52.1(h).


3

WHEREFORE, plaintiff prays for relief, as hereinafter set forth.

FIFTH CAUSE OF ACTION

Declaratory Judgment, 28 U.S.C. 2201

54.

The League repeats and realleges each and every allegation in paragraphs 1 through

7 57as if fully set forth herein.


8

55.

The City and the Chief continue to enforce Section 1070(h) of the Los Angeles

9 Charter, an unconstitutional provision governing the composition of any Board of Rights.


10

56.

As a result, the Leagues members are routinely deprived of their constitutional right

11 to a neutral decision-maker. Without appropriate relief, these members will continue to suffer
12 adverse employment decisions following unconstitutionally biased hearings.
13

57.

Accordingly, there exists a justiciable controversy between the Parties with respect

14 to the outcome, permanency, and future handling of Board of Rights hearings.


15

58.

By reason of the foregoing, the League requests a declaration that Section 1070(h)

16 of the Los Angeles City Charter violates the Fourteenth Amendment to the United States
17 Constitution.
18

WHEREFORE, plaintiff prays for relief, as hereinafter set forth.

19

V.

PRAYER FOR RELIEF

20

For the foregoing reasons, the League demands judgment against Defendants as follows:

21

(i)

On the first and second causes of action, pursuant to 42 U.S.C. 1983, a judgment

22 awarding the League injunctive relief and ordering that: (1) Los Angeles Charter Section 1070(h)
23 violates the Fourteenth Amendment to the United States Constitution; (2) all matters heard by a
24 Board of Rights during the pendency of this case are deemed void; (3) all matters pending before a
25 Board of Rights at the conclusion of this case are stayed, pending reformation of the Board of Rights
26 process; and (4) good cause exists under Los Angeles Charter Section 1070 (t) for a rehearing.
27

(ii)

On the third and fourth causes of action, for violation of the article 1, Section 15 of

28 the California Constitution and California Civil Code section 52.1, a judgment awarding the League
-10COMPLAINT

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1 expenses, costs and disbursements, and injunctive relief, and ordering that: (1) Los Angeles Charter
2 Section 1070(h) violates article 1, Section 15 of the California Constitution and California Civil
3 Code section 52.1; (2) all matters heard by a Board of Rights during the pendency of this case are
4 deemed void; (3) all matters pending before a Board of Rights at the conclusion of this case are
5 stayed, pending reformation of the Board of Rights process; and (4) good cause exists under Los
6 Angeles Charter Section 1070 (t) for a rehearing.
7

(iii)

Attorneys fees, costs, expenses pursuant to 42 U.S.C. 1988, California Code of

8 Civil Procedure section 1021.5, California Government Code section 800 or any other basis.
9

(iv)

For violation of California Civil Code 52.1, statutory damages and reasonable

10 attorneys fees.
11

(v)

On the Third Cause of Action, pursuant to 28 U.S.C. 2201, a judgment finding that

12 that Section 1070(h) of the Los Angeles City Charter violates the Fourteenth Amendment to the
13 United States Constitution and article 1, Section 15 of the California Constitution.
14

(vi)

And awarding the League such other and further relief as the Court deems just,

15 equitable and proper.


16
17

JURY DEMAND
The League herein demands a trial by jury of all triable issues.

18 Dated: May 19, 2016

SILVER, HADDEN, SILVER & LEVINE

19
20

By

21

/s/ Jacob Kalinski


Stephen H. Silver
Jacob Kalinski

22
23

MESSING ADAM & JASMINE LLP

24
25
26
27

By

/s/ Gregg McLean Adam


Gregg McLean Adam
Jennifer S. Stoughton
Attorneys for Attorneys for Plaintiff Los Angeles
Police Protective League

28
-11COMPLAINT

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