Association for Los Angeles Deputy Sheriffs v. County of Los Angeles
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ALADS appealed the trial court's decision sustaining a demurrer to ALADS's complaint without leave to amend. In this case, ALADs filed suit against the county over the county's alleged breach of a labor agreement.
The Court of Appeal reversed the trail court's decision sustaining the demurrer on the ground that ALADS failed to exhaust the administrative remedies available under the labor agreement before filing suit. The court held that, although ALADS was not exempt from the exhaustion requirement merely because it filed this action in its own name, the inadequacy exception to the exhaustion doctrine applied in this case because the individual remedies under the memorandum of understanding (MOU) were inadequate.
The court also held that if ALADS elects to pursue its fourth, fifth, and eighth causes of action, it must first pursue those claims with the Los Angeles County Employee Relations Commission (ERCOM); ALADS's claims for declaratory relief in its seventh, ninth, and tenth causes of action were moot; ALADS may amend its third cause of action to join parties necessary to seek a writ of mandate; ALADS's second cause of action for breach of contract stated a claim; and ALADS's eleventh cause of action for breach of the covenant of good faith and fair dealing asserted a claim.
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