Payne v. City of Perris (1993) 12 Cal.App.4th 1738 invalidated a pursuit policy substantially identical to the one at issue in Colvin v. City of Gardena (1992): "A policy which merely memorializes the unfettered discretion to initiate or terminate a pursuit or which allows each officer to use his or her own subjective standards for determining when a pursuit should be initiated, continued or terminated fails to provide any entity control. . . .. . . At the very least it should instruct and direct the officers on what factors should be considered in deciding whether to pursue the fleeing suspect." (Id. at p. 1747.)