In McManigal v. City of Seal Beach (1985) 166 Cal. App. 3d 975, the officer received an additional five percent "skill" pay as a motorcycle officer. At some point the department started noting performance deficiencies and rated the officer as needing improvement. Evaluations criticized the quantity of the work the officer performed and noted he "bent the rules" so he could spend more time riding his motorcycle. The officer's performance did not improve and the department reassigned him to a patrol car and as a result he lost his five percent "skill" pay. The appellate court found, although the officer did not lose any rank, he was transferred to a lower paying position as a "result of his perceived deficient performance." Accordingly, the appellate court held he was entitled to an administrative appeal under Government Code section 3304, subdivision (b). (McManigal v. City of Seal Beach, supra, 166 Cal. App. 3d 975, 981.)