Runyan v. Ellis (1995) 40 Cal.App.4th 961, was a case involving disciplinary action against a police officer for deficient performance. In Runyan the Long Beach Police Department filed an internal affairs complaint against the officer for deficient performance. In addition, the city sent him a formal letter of reprimand listing six incidents of Runyan's alleged failures to meet department standards as a peace officer. The officer received a temporary transfer and a cut in pay. The appellate court held "Runyan had a right to an administrative appeal because his 90-day transfer with accompanying cut in pay was 'punitive action' pursuant to section 3303." (Runyan v. Ellis, supra, 40 Cal.App.4th 961, 964.)