Quintanar v. Co. of Riverside

CourtCalifornia Court of Appeal
DecidedOctober 24, 2014
DocketE058232
StatusPublished

This text of Quintanar v. Co. of Riverside (Quintanar v. Co. of Riverside) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Quintanar v. Co. of Riverside, (Cal. Ct. App. 2014).

Opinion

Filed 10/15/14; pub. & mod. order 10/24/14 (see end of opin)

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION TWO

JOSE QUINTANAR,

Plaintiff and Respondent, E058232

v. (Super.Ct.No. RIC1119087)

COUNTY OF RIVERSIDE et al., OPINION

Defendants and Appellants.

APPEAL from the Superior Court of Riverside County. Sharon J. Waters, Judge.

Reversed.

Ferguson, Praet & Sherman and Anthony M. Snodgrass for Defendants and

Appellants.

Stone Busailah, Michael P. Stone, Muna Busaila, and Robert Rabe for Plaintiff

and Respondent.

1 The County of Riverside and the Riverside County Sheriff’s Department

(collectively Department) demoted Deputy Jose Quintanar as a result of an incident in

which Quintanar allegedly used excessive force. Pursuant to the applicable

Memorandum of Understanding (MOU), Quintanar filed an administrative appeal. This

triggered an evidentiary hearing before an impartial hearing officer. The hearing officer

agreed that Quintanar had used excessive force and upheld the demotion.

Quintanar then filed a petition for writ of mandate. The trial court, sua sponte,

questioned whether the hearing officer was required to exercise independent judgment

with respect to the nature of the discipline to be imposed, and if so, whether he had, in

fact, done so. It remanded the matter to the hearing officer with directions to clarify

whether he had exercised independent judgment. On receiving his reply, it determined

that he had not exercised independent judgment and it issued a writ commanding him to

do so.

The Department appealed. We agree with the trial court that, under the MOU, the

hearing officer was required to exercise independent judgment not only with respect to

whether there were grounds for discipline, but also with respect to the nature of the

discipline. We disagree with the trial court’s conclusion, however, that the hearing

officer’s failure to use independent judgment was prejudicial. The hearing officer did

indicate that, while he did not believe that he was required to exercise his independent

judgment, the exercise of his independent judgment would not have changed the

outcome.

2 Hence, we will reverse.

I

FACTUAL AND PROCEDURAL BACKGROUND

A. The Memorandum of Understanding.

The 2008-2011 MOU between the Riverside Sheriffs’ Association, Inc. and the

County of Riverside provided: “Any employee may appeal any disciplinary action taken

against the employee.”

An appeal is to be heard by a hearing officer. The hearing officer is selected from

a list of persons previously agreed to by both parties. The hearing officer must hold an

evidentiary hearing, at which both sides have the right to call and examine witnesses, to

cross-examine the witnesses for the other side, and to introduce exhibits. After the

hearing, the hearing officer must “submit written findings of fact, conclusions of law, and

the decision . . . . The decision of the Hearing Officer shall be final subject to the right of

either party to seek judicial review under Section 1094.5 of the California Code of Civil

Procedure.”

“The Hearing Officer may sustain, modify, or rescind an appealed disciplinary

action . . . .” “If the Hearing Officer finds that the disciplinary action was appropriate,

the action shall be sustained.”

3 B. Quintanar’s Demotion.

Quintanar worked for the Sheriff’s Department of the County of Riverside as a

correctional deputy. On September 28, 2009, he was involved in an incident in which he

allegedly used excessive force against an arrestee.

The Department conducted an investigation. The investigation included

interviews with eyewitnesses, including Quintanar, and the review of a video of the

incident. The investigation concluded that Quintanar had, in fact, used excessive force.

On January 11, 2010, the Department sent Quintanar a notice of intent to demote

him based on inefficiency or negligence, willful violation of an employee regulation, and

conduct adversely affecting department operations. Quintanar requested a Skelly

hearing;1 one was held on February 23, 2010. On February 24, 2010, the Department

demoted Quintanar, effective March 11, 2010.

C. Proceedings Before the Hearing Officer.

Pursuant to the MOU, Quintanar filed an administrative appeal. The key issue in

the administrative appeal, as stipulated by the parties, was, “Was there just cause to

demote . . . Quintanar?”

The hearing officer held a three-day evidentiary hearing. During the hearing,

Chief Deputy Steve Thetford testified that he was the one who made the decision to

1 A Skelly hearing is an opportunity for the employee to respond to the decision maker regarding the charges against him or her. (Skelly v. State Personnel Bd. (1975) 15 Cal.3d 194, 206.)

4 demote Quintanar. He had considered the Department’s “disciplinary matrix,” which

provides “generic guidelines” for the appropriate level of discipline. For example, for

“use of force with injury,” as in this case, it provides for an 80-hour suspension.2

Nevertheless, he decided to demote Quintanar instead, because, in his view, “the

egregious nature” of Quintanar’s use of force made it “not an act that . . . [an officer of

Quintanar’s rank] should be conducting.”

On September 21, 2011, the hearing officer denied the administrative appeal. He

agreed that Quintanar had used excessive force.

Regarding the appropriate discipline, the hearing officer stated: “[I]t is not

appropriate to substitute my judgment for that of the decision maker. Rather, my

function is to consider whether the imposed discipline is arbitrary and/or is within the

range of discipline that would be reasonable for the proven misconduct.”

He continued: “The disciplinary matrix should be given great consideration and

deference since it is the Department’s notice to employees concerning the discipline that

might be imposed for certain types of misconduct.” He noted that discipline outside the

disciplinary matrix, standing alone, might be deemed arbitrary. He also noted, however,

that Chief Deputy Thetford had explained why he had decided to demote Quintanar. He

concluded that Quintanar’s own inconsistent testimony “mitigated against any inclination

2 It is not entirely clear whether the disciplinary matrix actually prescribed an 80-hour reduction in compensation or an 80-hour suspension. For purposes of our opinion, however, the distinction is not significant.

5 that may have otherwise existed to reduce the severity of the discipline” because it

“demonstrated his lack of understanding of the inappropriateness of his misconduct and

his failure to take responsibility for his actions.”

D. Proceedings in the Trial Court.

Quintanar filed a petition for writ of mandate, alleging, among other things, that

the discipline imposed was excessive.

At the argument on the petition, the trial court raised the issue sua sponte of

whether the hearing officer erred by concluding that he should not exercise independent

judgment regarding the appropriate discipline.

Counsel for Quintanar, adopting the trial court’s suggestion, argued that the

hearing officer had indeed erred by failing to exercise his independent judgment.

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Related

Skelly v. State Personnel Board
539 P.2d 774 (California Supreme Court, 1975)
Olson v. Cory
673 P.2d 720 (California Supreme Court, 1983)
Talmo v. Civil Service Commission
231 Cal. App. 3d 210 (California Court of Appeal, 1991)
Thornbrough v. Western Placer Unified School District
223 Cal. App. 4th 169 (California Court of Appeal, 2013)
Santa Clara County Correctional Peace Officers' Ass'n v. County of Santa Clara
224 Cal. App. 4th 1016 (California Court of Appeal, 2014)
Kolender v. San Diego County Civil Service Commission
132 Cal. App. 4th 1150 (California Court of Appeal, 2005)

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