Garcia v. State Dept. of Developmental Services
Annotate this CaseThis case concerned the statute of limitations in the California Public Safety Officers Procedural Bill of Rights Act. One of these protections was described in Government Code section 3304 (d)(1): a public agency cannot discipline a peace officer “for any act, omission, or other allegation of misconduct” unless the agency completes its investigation and notifies the officer of its proposed discipline “within one year of the public agency’s discovery by a person authorized to initiate an investigation of the allegation of an act, omission, or other misconduct.” Under the interpretation offered by appellant Luis Garcia, section 3304(d)(1)’s one-year limitations period begins to run on all acts of misconduct once the agency initiates an investigation into any one of these acts. But under the second interpretation, offered by Garcia’s employer, the limitations period begins to run on an act of misconduct only once the agency discovers that particular act. The Court of Appeal determined the latter interpretation was the correct one: Section 3304(d)(1)’s text was "clear" that the limitations period for an act of misconduct begins to run on the date the agency discovers the misconduct, not the date it initiates an investigation into unrelated misconduct. Under this rule, as under similar discovery rules, each act of misconduct must be considered separately in determining the date the agency discovered the misconduct. Because the trial court here interpreted section 3304(d)(1) consistent with the Court of Appeal's interpretation, the judgment was affirmed.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.