In Zeron v. City of Los Angeles (1998) 67 Cal. App. 4th 639, which involved the termination of a Los Angeles police officer, the court explained the distinction between a probationary officer and a tenured officer in the context of termination: "A tenured officer may only be discharged for cause, after having received a full hearing. In the City, such a board of rights hearing is held before a three-person panel. . . . The burden is on the department to prove its case by a preponderance of the evidence. After the hearing, the chief of police may impose a lesser penalty than suggested by the panel but not a greater one. On the other hand, a probationary officer may be terminated without cause. However, if the reason or reasons behind the discharge would tend to besmirch the officer's reputation and negatively impact on future employment, the officer is entitled to a 'liberty interest' hearing to clear his or her name. Although the procedural rules vary from city to city , a 'liberty interest' hearing involving a police officer is generally held before a single hearing officer, whose recommendation may be adopted, ignored, or modified by the chief of police. " ( Id. at pp. 641-642.)