County of Sutter v. Board of Administration

In County of Sutter v. Board of Administration (1989) 215 Cal.App.3d 1288, the Court held that family support investigators employed by the Sutter County District Attorney's Office were not safety officers, because their principal duties did not clearly fall within the scope of active law enforcement service. The Court reached this conclusion, acknowledging the fact that the investigators interviewed witnesses, prepared complaints and petitions for civil actions, arranged blood tests and necessary transportation, assisted in trial preparation of civil actions to establish and enforce child support obligations, and served papers in connection with the litigation. (Id. at pp. 1291-1292.) Noting that special retirement benefits are granted to safety officers in recognition of the hazards and stresses of their daily employment and citing Crumpler's edict that active law enforcement means " 'law enforcement services normally performed by police, ... the active enforcement and suppression of crimes and the arrest and detention of criminals,' " we held that the principal duties of the family support investigators could not be characterized as active law enforcement service. (County of Sutter, at p. 1293.)