Hudson v. County of Los Angeles

In Hudson v. County of Los Angeles (2014) 232 Cal.App.4th 392, the reviewing court distinguished Zuniga and Latham given the unique, and somewhat tortured, factual chronology involved there. Hudson concerned the civil service appeal of a discharged deputy sheriff who, during the pendency of her appeal, was placed on "statutorily mandated" disability retirement by her employer, not by her own choice. (Hudson, at p. 413.) The record before the Commission demonstrated the former deputy had since been cleared for full duty by a physician, and the hearing officer had determined the deputy's discharge had been unjustified. Hudson concluded, given the factual record there, that the former deputy's disability retirement did not equate with an "unequivocal intention" to sever her employment with the county, unlike the voluntary retirements at issue in Zuniga and Latham, and should not result in her discharge being immunized from review by the Commission. (Hudson, at p. 413.)