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CASE
UPDATES
By: Martin J. Mayer
&
Mervin D. Feinstein
Agreement Between Sheriff and County Does
not Change Correctional Officers To Deputy Sheriffs
ABBATE
et al. v. COUNTY OF SANTA CLARA et al.
91 Cal.App. 4th 1231 111 Cal.Rptr. 2d 412 (2001)
In April 1997, after two unsuccessful attempts to provide armed correctional
officers in the Santa Clara County jail when control of the jail was
transferred from the Sheriff to the newly formed county Department of
Correction, the County and the Sheriff's Office entered into an agreement
transferring correctional officers and the transportation and security
functions requiring armed officers to the Sheriff. The Sheriff agreed
to "appoint correctional officers as deputies to perform transportation,
security or other correctional officer functions with such peace officer
authority as conferred by law ... ."
Thereafter, the Santa Clara County Correctional Peace Officers' Association
sought declaratory relief to establish that these officers were deputy
sheriffs with Penal Code section 830.1(a) peace officer status. The
Correctional Peace Officers' Association also requested a writ of mandate
directing the County to provide state mandated POST training.
The trial court found that correctional officers were not deputy sheriffs
and denied extraordinary relief. The California Court of Appeal, Sixth
Appellate District affirmed the trial court's finding that the correctional
officers did not become Penal Code section 830.1(a) deputy sheriffs
under the agreement.
The Court noted that whether a person employed by the Sheriff is a
section 830.1(a) "deputy sheriff" is based upon "the work to be performed
or the duties to which one may be assigned that determines his status
as an officer or employee." The Court pointed out that section 830.1(a)
contemplates the possibility of a lesser delegation when it confers
peace officer status on "[a]ny sheriff, undersheriff, or deputy sheriff,
employed in that capacity, ... " Thus, an employee of the sheriff
not required to perform the duties of a deputy sheriff, as "otherwise
provided for" (GC 1194), is not "employed in that capacity" (830.1(a)),
and is not a deputy sheriff with full peace officer powers.
How this affects your agency: This is the culmination
of a problem that has existed since 1988, when the voters of Santa Clara
County approved a charter amendment transferring responsibility for
the county jails from the Sheriff to the Department of Correction. The
Department of Correction, a law enforcement agency, was established
pursuant to GC 23013 and was vested with the same authority as the sheriff
with respect to institutional punishment, care, treatment and rehabilitation
of prisoners. However, certain functions performed in the jail such
as transporting prisoners, pursuing escaped prisoners, conducting searches
and seizures and arrests, and supervising the custodial officers, require
officers who are authorized to carry firearms. Agencies that maintain
jail facilities and employ "correctional officers," "jailers," etc.,
would do well to review the following cases, in addition to this one,
County of Santa Clara v. Deputy Sheriffs' Assn. 3 Cal.4th 873 (1992);
People ex rel. Deputy Sheriffs' Assn. V. County of Santa Clara, 49 Cal.App.4th
1471 (1996).
*********
Termination Based on Failed Mandated DOT Drug
Test Cannot Stand Where Medical Review Officer Was An Imposter
SOUTHERN CALIFORNIA GAS CO. v. UTILITY WORKERS UNION OF
AMERICA, LOCAL 132, AFLCIO 265 F. 3d 787 (2001)
Two utility workers were terminated after Southern California Gas, their
employer, learned from its medical review officer, whom the company believed
was a licensed physician, that both had failed federally required random
drug tests. Shortly thereafter, the medical review officer was arrested
for impersonating a licensed physician. Once the union learned that the
medical review officer was an imposter, it pressed for the workers' reinstatement.
Southern California Gas refused and arbitration ensued pursuant to a collective
bargaining agreement.
The arbitrator found in the workers' favor and ordered reinstatement.
Southern California Gas dissatisfied with the arbitrator's result sought
to have the award vacated. The district court denied SCG's motion to vacate.
The United States Court of Appeals, Ninth Circuit, affirmed and upheld
the arbitrator's findings.
The Court pointed out that only where an arbitrator ignores a contract's
plain language, choosing instead to dispense his own brand of industrial
justice, can it question his judgement. The Court noted the relevant issue
that was before the arbitrator was not whether the workers had in fact
taken prohibited drugs, but rather whether their drug tests were properly
administered so as to justify the loss of their employment. Under 49 C.F.R. § 40.33(a)(1). governing Medical Review Officer review, the regulation
clearly requires certification of a positive test by a licensed physician,
the Medical Review Officer, before the company is told and therefore before
discipline is imposed.
The Court opined that the DOT regulations at issue did not exist in a
vacuum. Once the government required an employer to administer random
drug tests to a certain class of workers, the Fourth Amendment is implicated;
thus, the "search" effected by a urine test is subject to the Fourth Amendment's
reasonableness requirement. To excuse noncompliance with the regulations
- or to adopt a substantial compliance standard - may have the unintended
effect of vitiating an individual's Fourth Amendment rights.
How this affects your agency: This case affirms the employer's
responsibility to comply with requirements of legislatively mandated substance
testing which, as the court points out in this instance, would require
the employer to guarantee an employee's right to privacy by verifying
that the individual holding himself out as a licensed physician was, in
fact, licensed. The reinstatement did not relieve the employee of having
to subject himself to continued random drug testing as required by DOT
regulations for safety sensitive positions.
*********
Continuing Violation Doctrine Allows
Disability Discrimination Over One-Year
Statute of Limitations To Proceed
RICHARDS v. CH2M HILL, INC. 26 Cal. 4th
798 29 P. 3d 175 111 Cal. Rptr. 2d 87 (2001)Lachi Delisa Richards was
hired as a civil engineer in 1984 by CH2M Hill, Inc., a nationwide engineering
firm. In late 1987 Richards began experiencing tremors and difficulty
walking. Although she could still walk, she began using a wheelchair in
April 1988 as a means of conserving energy. In October 1988, Richards
was diagnosed with multiple sclerosis (MS). Richards's supervisors initially
agreed to her request that she be given a part-time schedule, that she
not be required to perform any fieldwork, and that she be permitted to
work out of the Sacramento office. Richards's symptoms continued to worsen
and, on her doctor's advice, she took an indefinite leave of absence which
ultimately lasted 10 months.
On January 2, 1990, Richards returned to work and as her condition improved,
she eventually worked an average of 20 to 25 hours per week. She performed
some of her work at the office and some of her work at home - a routine
that continued until February 1993, when she tendered her resignation.
Richards sued for disability discrimination. When she requested a formal
transfer, a process which normally takes 60 to 75 days, approval of her
transfer took 11 months. When, acting on her doctor's advice, she requested
the purchase of a bed so that she could rest during her breaks and at
lunchtime, the company purchased a folding army cot. One of the company's
administrators, Carol Uhouse, insisted that Richards help pay for items
such as a mattress and sheets, while the company paid for blankets and
a pillow. Richards's office was also moved to a "storage/layout kind of
all purpose junk room area." The jury found in Richards favor, awarding
substantial sums as damages to compensate for severe emotional distress
and lost salary; the Court of Appeal affirmed the decision. The California
Supreme Court reversed and remanded.
Many of the incidents of disability discrimination introduced at trial
occurred outside the one-year limitation period for filing Fair Employment
and Housing Act actions. Addressing the question whether an employer can
be held liable for unlawful actions occurring outside the limitations
period for bringing an action under the Fair Employment and Housing Act
(Government Code § 12900 et seq.), the Court noted that the "continuing
violation doctrine" allows liability for unlawful employer conduct occurring
outside the statute of limitations, if it is sufficiently connected to
unlawful conduct within the limitations period.
The California Supreme concluded that, consistent with the language and
purposes of the Fair Employment and Housing Act, as well as federal and
California case law, an employer's series of unlawful actions in a case
of failure to reasonably accommodate an employee's disability, or disability
harassment, should be viewed as a single, actionable course of conduct
if (1) the actions are sufficiently similar in kind; (2) they occur with
sufficient frequency; and (3) they have not acquired a degree of "permanence" so that employees are on notice that further efforts at informal conciliation
with the employer to obtain accommodation or end harassment would be futile.
How this affects your agency: The Court reaffirmed that
where conduct of the same or similar nature continues over a prolonged
period of time, the statute of limitations cannot be used as a defense
and will be viewed by the courts as a single, actionable course of conduct.
Agencies, regardless of size, must make every reasonable attempt to insure
all administrators, managers and supervisors follow a reasonable standard
in accommodating employees with disabilities.
*********
Civil/Civil Rights
No Mandatory Duty To Prevent
Adolescent From Running Away From
Protective Custody Children's Center
WILSON v. CO. OF SAN DIEGO 91 Cal.App. 4th
111 Cal. Rptr. 2d (2001)
After telephoning 9-1-1 and reporting that his grandfather, which whom
he was living, was drunk and had struck him on the head with the telephone,
Michael Wilson, a 13 year old, was taken to Polinsky Children's Center,
by local police. The following afternoon, Michael telephoned his father
in Northern California and asked to be picked up and was told he couldn't
come and get him right now. Michael became angered and said he was going
to take off or that he was going to kill himself, and hung up on his father.
The father did not inform Polinsky staff about Michael's threat. That
evening, unbeknownst to its staff, Michael ran away from Polinsky and
was seriously injured when he darted onto a busy thoroughfare.
Michael, through his father as guardian ad litem, sued San Diego County
for negligence and negligent infliction of emotional distress, alleging
that children taken into protective custody are "in extreme emotional
states, frightened, paranoid, insecure, and subject to running away," and thus it was foreseeable he was at such risk and the County had a duty
to prevent him from running away from the shelter. San Diego County moved
for summary judgment, arguing there is no statutory basis for its liability.
The court granted the motion, finding San Diego County sustained its burden
of showing that Michael could not establish the essential element that
the County breached a mandatory duty owed him.
The California Court of Appeal, Fourth Appellate District affirmed the
trial court holding that the County and its employees did not have a mandatory
duty to prevent an adolescent from running away from Polinsky Children's
Center. The Court pointed out that the California Tort Claims Act bars
liability against public agencies and their employees except as specifically
provided by statue. Government Code § 815.6 provides: "Where a public
entity is under a mandatory duty imposed by an enactment that is designed
to protect against the risk of a particular kind of injury, the public
entity is liable for an injury of that kind proximately caused by its
failure to discharge the duty unless the public entity establishes that
it exercised reasonable diligence to discharge the duty."
Although Michael asserted that WIC § 300.2 imposed a mandatory duty on
the County and it's employees to stop him from running away, the Court
pointed out that the California Supreme Court has held that application
of Government Code § 815.6 requires that the enactment at issue be obligatory,
rather than merely discretionary or permissive, in its directions to the
public entity; it must require, rather than merely authorize or permit,
that a particular action be taken or not taken. The Court then noted that
WIC § 300.2 does not require a public agency to take any particular action.
Rather, it recites legislative goals and policies that must be implemented
through a public agency's exercise of judgment. It cannot reasonably be
interpreted to impose a mandatory duty on public agencies to guarantee
the safety of dependent children in all circumstances. In this case, Michael
was not a criminal and he was placed in a non-secure facility.
How this affects your agency: Injury to juveniles escaping
from custody has been a continual source of liability worry for not only
street officers but also probation personnel. This case closes the loop
which started five years ago when the California Supreme Court held in
Ladd, a Minor v. Co. of San Mateo, 12 Cal.4th 913
(1996), that the immunity provided public entities and employees by Government
Code § 845.8, subdivision (b), from liability for any injury "caused by"
an escaping prisoner applies when a prisoner injures herself during an
attempted escape. Here Michael is not a "prisoner" but is being detained
under WIC § 300, et seq., the other side of the juvenile detention coin.
Although there may not be liability attached, personnel should not develop
a cavalier attitude concerning the safety of anyone, especially juveniles,
taken into custody. The key will always be whether any act of commission
or omission was reasonable.
*********
Criminal
Search Warrant For Residence May Include
All Buildings Within Curtilage Even If
Not Specifically Referenced
US v. CANNON, 264 F. 3d 875 (2001)
DEA Special Agent Collette drafted an affidavit and a search warrant seeking
authorization to search 1250 Hemlock Street in Chico, after obtaining
incriminating evidence from a cooperating witness concerning the owner
of the property, Michael Cannon. Attachment A to the warrant describes
the place to be searched as "a double story, single family dwelling, sand
wooden structure with brown trim and dark gray composite style roof; further
identified by the three inch black numbers '1250' affixed to the house,
facing hemlock street." Attachment B authorized the seizure of property
that included, among other things: "7. Articles of personal property,
such as ... vehicles, structures, storage areas, residences or containers
where marijuana or evidence may be found."
At the time of the application Agent Collette knew that there were two
structures within the fence that surrounded 1250 Hemlock Street, but failed
to so inform the magistrate judge because he reasonably assumed that the
second structure was a garage. Collette did not specify the rear building
as a place to be searched.
Cannon had converted the rear building from a garage into a self-contained
residential unit approximately twenty years earlier without obtaining
the proper building permits. The City of Chico did not have the rear building
registered as a lawful second unit.
DEA agents executed the search warrant and after entering the main house
and placing Cannon under arrest, searched both the main house and the
rear building's dwelling area. Finding no incriminating evidence in the
dwelling area the officers exited the rear building and tried the doors
to the building's storage rooms. Finding them locked, the officers went
inside and asked Cannon for the keys. Upon opening the two storage rooms,
the officers found and seized approximately four hundred marijuana plants.
At Cannon's evidentiary hearing Steve Cook testified that he rented the
rear building's residential unit from Cannon, his occupancy included the
time of the search warrant. Cook also testified that he used the unit
as a part-time living space, and that his rental pertained only to the
interior dwelling area in the back building. Cook's rental did not include
the two storage rooms where the marijuana was found. The district court
determined that the rear building storage rooms were not within the scope
of the warrant and ordered that the marijuana be suppressed.
The United States Court of Appeals, Ninth Circuit reversed concluding
that a search warrant for a residence may include all other buildings
and other objects within the curtilage of that residence, even if not
specifically referenced in the search warranted. The Court reasoned that
the entire rear building at 1250 Hemlock qualifies as curtilage of Cannon's
residence under United States v. Dunn, 480 U.S. 294 (1987). The
Court pointed out that because Steve Cook possessed a reasonable expectation
of privacy in the rear building rooms he rented, those spaces exceeded
the scope of the search warrant for Cannon's residence.
Cook on the other hand had no expectation of privacy in the two storage
rooms where the DEA discovered marijuana. Cannon did have such an expectation.
Therefore, the Court opined, there was no reason to exclude from the curtilage
of Cannon's residence the storage rooms where marijuana was found.
How this affects your agency: Personnel involved in investigations
that culminate with the execution of a search warrant must be vigilant
in the gathering of supporting data for their affidavit. The judicial
officer approached should always be given any and all relevant information.
The use of knowledgeable prosecutors cannot be over emphasized in these
situations.
*********
Civil/Civil Rights
Information Does Not Have To Be Part
Of Investigative File To Be Exempt From Disclosure
HAYNIE v. SUPERIOR COURT OF L.A. CO. (LASD) 26
Cal. 4th 1061 31 P. 3d 760 112 Cal. Rptr. 3d 80 (2001)
Haynie, a 42 year old Black male, was driving a blue Ford van with three
teenage Latina passengers when he was stopped by a Los Angles County Deputy
Sheriff. Minutes earlier, a citizen had reported three teenage Asian males
getting into a blue Ford van with what she believed were pistols or squirt
guns. Haynie was handcuffed, he and the three passengers were questioned
and the van was searched. Haynie and the three passengers were eventually
released with no charges filed against them. Haynie, who claimed he was
injured during the course of the questioning presented a tort claim to
the County and filed a citizen's complaint with the Sheriff's Department.
Haynie also submitted a "Demand for Public Records" for "any writings"
concerning the incident. The sheriff's department refused to provide any
records, claiming the exemption of Government Code section 6254(f), and
did not identify any records withheld. The department instead disclosed
certain information in a "summary of the event."
Haynie next filed a "Verified Petition for Order Compelling Disclosure
of Public Records and Materials" under Government Code section 6258, and
a "Motion for Order Compelling Disclosure of Public Records and Materials
and for Award of Statutory Attorney's Fees and Costs." At a hearing to
consider the petition and the County's opposition thereto the trial court,
after argument, ruled from the bench that the matter was governed by 6254(f)
which was not a pre-litigation discovery statute.
The Second District Court of Appeals issued a peremptory writ of mandate
directing the superior court to vacate its denial order and reconsider
the petition and motion, holding that the exemption for records of investigations
applies only when the prospect of enforcement proceedings is concrete
and definite. Concluding that no such prospect existed for the records
created before or during the stop, the court directed the trial court
to "determine whether the records in question exist and, if so, order
their disclosure."
The California Supreme Court concluded that the Court of Appeal erred
in directing disclosure of the records and ordering the County to create
a log of documents exempt from disclosure and reversed the judgment granting
the petition for writ of mandate.
The Court pointed out that limiting the section 6254(f) exemption only
to records of investigations where the likelihood of enforcement has ripened
into something concrete and definite would expose to the public the very
sensitive investigative stages of determining whether a crime has been
committed or who has committed it. The Court also noted that requiring
a public agency to provide a list of all records in its possession that
may be responsive to a California Public Records Act (CPRA) request, has
the potential for imposing significant costs on the agency. The Supreme
Court concluding that the Court of Appeal also erred in holding that such
inventories or lists must be created as a matter of course as part of
the agency's initial response to CPRA requests.
How this affects your agency: Government Code § 6254(f)
requires certain information be made available from public records. The
California Supreme Court reaffirmed that information, not the records,
must be provided, such as the "substance" of complaints and the "factual
circumstances surrounding the crime or incident." Therefore agencies can
maintain compliance with Government Code § 6255 by demonstrating that
a record falls within a statutory exemption, or that the public interest
in non-disclosure clearly outweighs the public interest in disclosure.
Section 6255 does not require an agency to describe each of the documents
falling within the statutory exemption.
*********
Ninth Circuit Affirms No Excessive
Force
By Police In Quelling Disturbance
JACKSON v. CITY OF BREMERTON (Washington) et.al.
268 F. 3d 646 (2001)
Jackson and 30 to 50 friends and family members gathered at a public park.
Officers, patrolling the area on bicycles, responded to a report that
the group was consuming alcohol. While speaking with members of the Jackson
party, Officer Dahlberg recognized Jackson's son, Kevin Blake, from previous
contacts. Officer Dahlberg checked Blake's name for wants and learned
that there was an outstanding robbery warrant. Blake was informed of the
outstanding warrant and Blake's mother began arguing with the officers
regarding the nature of the warrant. Blake ran into the large group of
people and tried to run out of the park. Several of his friends attempted
to shield him from arrest and Officer Eriksen called for additional backup
due to the escalating situation.
As officers arrived and continued to attempt to apprehend Blake, Jackson
and her group yelled, swore and advanced upon them. A fight ensued between
an officer and a 17 year old female family friend of Jackson's. Witnessing
the altercation, Jackson ran to interfere with the female officer and
Jackson was sprayed with a chemical irritant. Jackson was then placed
under arrest for failure to disperse. Officers had warned everyone in
advance that a chemical irritant would be used if the group did not disperse.
Jackson was sprayed with water to remove the chemical irritant and given
immediate medical attention while at the station. She noticed swelling
in her fifth finger when her handcuffs were removed and the finger was
subsequently found to be fractured.
As a result of the incident five, arrests were made and all five, including
Jackson, were convicted of various misdemeanors. Jackson and Blake filed
suit against the City, the Police Chief and officers alleging excessive
force. The district court granted summary judgment motions for all defendants
on all claims. The United States Court of Appeals for the Ninth Circuit
affirmed.
The court noted that, under the Fourth Amendment, officers may only use
such force as is "objectively reasonable" under the circumstances. To
determine whether the force used was reasonable it must be judged from
the perspective of a reasonable officer on the scene. The Court found
that, even assuming Jackson's version of the facts was correct, the nature
and quality of the alleged intrusions were minimal. The government's interest
began with an attempt to arrest Blake on an outstanding felony warrant.
The officers, who were substantially outnumbered, were faced with a group
that refused to obey the officers' command to disperse; that shouted at
the officers; and that engaged the officers in verbal and physical altercations.
The safety interest in controlling the group increased further when the
group was warned that a chemical irritant would be used if they did not
move back from the area, and the group refused to comply. Jackson, who
heard the warning, also chose to ignore the officers' orders, and instead
began to directly interfere with Officer Davis' attempts to maintain order.
Jackson's active interference posed an immediate threat to the officers'
personal safety and ability to control the group. Under the circumstances,
that Jackson herself described as a "melee," the force applied was reasonable
and necessary to control a "rapidly evolving" and escalating situation.
The Court found that because no Fourth Amendment violation occurred, the
district court properly granted summary judgment in the officer's favor.
How this affects your agency: This case reaffirms that
where officers act in a reasonable and responsible manner, (e.g., giving
those involved in a situation adequate warning of what is to come if they
persist in aggressive acts), force used to repel an immediate threat to
the officers' personal safety and ability to control the group will not
be deemed excessive. This case also recognized that officers are called
upon to make instant decisions in trying situations and their actions
should be judged on the situation, not with 20/20 vision hindsight or
in the peace and quiet of a judges chambers.
*********
Criminal Law/Procedure
Arrestee's Statements Made After Invoking Right To Counsel
May Be Used When Police Do Not Initiate Questioning
U.S. v. MICHAUD 268 F. 3d 728 (2001)
After a joint investigation by the FBI and Placer County Sheriff's
Department into a kidnaping and sexual assault, suspects Michaud and
her boyfriend, James Daveggio, were located at a motel in Stateline,
Nevada. Placer County secured warrants for their arrest and FBI Agent
Ferrin led a group of agents to the hotel the following day. An agent
knocked on Michaud's door, claimed to be the assistant manager of the
hotel and told her that her boyfriend was sick and needed her assistance.
In reality, Daveggio had already been apprehended. When Michaud opened
the door she was placed under arrest and taken to another room where
she was handcuffed to a chair. Agent Ferrin secured Michaud's signature
on consent forms to search her room and vehicle, advised her of her
Miranda rights, and she signed another form indicating she understood
and waived those rights.
FBI agents and Placer County detectives then proceeded to interview Michaud.
When she indicated she wanted to speak to a lawyer, the interview was
terminated and Michaud was booked into the Douglas County, Nevada jail
on the state warrant and for possession of controlled substances.
After learning that she and her boyfriend had been featured on a television
news report in connection with a murder Michaud became distraught and
began telling her cellmate, Agoroastos, she was scared and in a lot of
trouble. Agoroastos contacted Deputy Conrad over the intercom and said
that Michaud needed to talk to somebody. Douglas County Sergeant Minister
took Michaud to an interview room, where they met with FBI Agent Campion.
Michaud stated that she had some information about the young lady who
was killed. She was informed of her Miranda rights, including her right
to have an attorney present during questioning. Once she indicated that
she understood these rights and signed a waiver, they began to interview
her.
Placer County yielded priority of their prosecution to the federal government
and Michaud was indicted on charges of kidnaping and transportation across
state lines and conspiracy to commit the same. Michaud moved to suppress
the statements she made during her interviews with law enforcement officials,
and the district court denied the motion. Michaud entered a conditional
guilty plea on the kidnaping charge and was sentenced to 152 months in
prison. The United States Court of Appeals, Ninth Circuit affirmed the
district court's denied of Michaud's motion to suppress her statements.
The court dismissed Michaud's contention that the ruse the officers used
to persuade her to open the door of her hotel room violated her Fourth
Amendment rights - noting that she acknowledged that a valid warrant for
her arrest existed at the time of the ruse. The court pointed out that
it has previously held there was no constitutional mandate forbidding
the use of deception in executing a valid arrest warrant. Leahy v.
United States, 272 F.2d 487, 490 (9th Cir.1960); United States
v. Contreras-Ceballos, 999 F.2d 432, 435 (9th Cir.1993).
The court pointed out that in Edwards v. Arizona, 451 U.S. 477, 484-85
(1981), once an accused has invoked her right to counsel during interrogation,
she may not be subjected to further police interrogation "unless the accused
[her]self initiates further communication, exchanges, or conversations
with the police." Here, Michaud initiated further communication and the
police merely reacted to her; they were approached with information that
Michaud wished to speak about a murder. At no point did the law enforcement
officials unconstitutionally attempt to coerce Michaud into speaking with
them.
How this affects your agency: Where, as here, the rules
of engagement between law enforcement officials and suspects are followed,
not only will the actions of law enforcement be upheld, but incriminating
statements made by the suspect will not be suppressed. In all matters
where subsequent interrogations are to take place, officers should consult
with a prosecutor to lessen any chance of error.
*********
[The Law Offices
of Jones & Mayer located in Fullerton, California focus its practice
on representing the interests of public entities as its City Attorney,
in labor negotiations, in defending tort litigation and civil rights
litigation. Martin Mayer focuses his practice in the area of representing
cities, counties and the State on matters arising out of their respective
law enforcement agencies.]
As always, before taking any
legal actions be certain to seek appropriate legal advice, whether it
is from a city attorney, county counsel, or your police legal advisor.
If you have any questions or wish to discuss these cases in more detail,
please do not hesitate to call us at (714) 446-1400.
Caseupdt.000.Vol6#9
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