Association for Los Angeles Deputy Sheriffs v. County of Los Angeles
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ALADs sought a writ of mandate and declaration that a provision of the memorandum of understanding (MOU) between ALADS and the County of Los Angeles is unenforceable based on the ground that it violates wage garnishment law and the Labor Code. The trial court sustained the county's demurrer to the petition on the ground that ALADS did not exhaust administrative remedies.
The Court of Appeal concluded, in light of Association for Los Angeles Deputy Sheriffs v. County of Los Angeles (2019) 42 Cal.App.5th 918, that ALADS's administrative remedies are inadequate, and thus dismissal on that ground was improper. However, the court concluded that dismissal was proper because ALADS's petition does not state valid claims against the county. The court explained that the home rule doctrine gives the county the exclusive right to regulate matters relating to its employees' compensation. In this case, the county's MOU with ALADS, approved by the board of supervisors, is a lawful exercise of that exclusive right, and the Labor Code provision at issue does not apply to a charter county. Therefore, ALADS cannot allege sufficient facts to state a cause of action.
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