Baggett v. Gates

In Baggett v. Gates (1982) 32 Cal.3d 128, police officers who were demoted petitioned for a writ of mandate, alleging that they had not been afforded an administrative appeal as required by the Public Safety Officers Procedural Bill of Rights Act (the Act). ( Gov. Code, 3300 et seq.) The city for whom the officers worked argued that the Act did not apply to charter cities because it violated the home rule provisions of the California Constitution. ( 5.) Baggett contains some very convincing language about how the maintenance of stable employment relations between police officers and their employers is a matter of statewide concern. Specifically, Baggett talks about how the effects of labor unrest and strikes by police officers are felt beyond a city's borders, which is a major point made by RSA and amici curiae. This language initially appears to bolster RSA's position, but as explained below, the actual holding of Baggett stops well short of validating SB 402. The California Supreme Court in Baggett goes out of its way to point out that "the act does not interfere with the setting of peace officers' compensation." ( Baggett, supra, 32 Cal.3d. at p. 137.) Rather, the Supreme Court emphasizes that the Act "creates uniform fair labor practices throughout the state" and "secures basic rights and protections to . . . public employees . . . ." ( Id. at pp. 139-140.) The Supreme Court stops well short of endorsing state interference with local peace officer compensation, and implies that such interference would be much more serious than that necessary to ensure basic fair labor practices. Equally important, RSA cannot convincingly argue that having the power to compel arbitration of compensation issues is a "basic right" of public safety employees or that its absence is an unfair labor practice. Overall, then, despite its remarks about the multijurisdictional implications of unstable public safety employee labor relations, the California Supreme Court in Baggett declares only that ensuring fair labor practices and basic protections for public safety employees is a matter of statewide concern; it is not authority that the compensation of these employees is a matter of statewide concern. In sum, the officers worked in the firearms and explosives unit of the Los Angeles Police Department's scientific investigation division. Each of the officers had acquired extensive, specialized training and experience in the handling of firearms and explosives. The officers received extra compensation because these assignments were classified as both "advanced paygrade," as well as hazardous. (Baggett v. Gates, supra, 32 Cal.3d 128, 131-132.)