Riggs v. City of Los Angeles CA2/3

CourtCalifornia Court of Appeal
DecidedDecember 22, 2025
DocketB338162
StatusUnpublished

This text of Riggs v. City of Los Angeles CA2/3 (Riggs v. City of Los Angeles CA2/3) 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
Riggs v. City of Los Angeles CA2/3, (Cal. Ct. App. 2025).

Opinion

Filed 12/22/25 Riggs v. City of Los Angeles CA2/3 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION THREE

BARBARA RIGGS, B338162

Plaintiff and Appellant, Los Angeles County Super. Ct. No. v. 22STCP02841

CITY OF LOS ANGELES et al.,

Defendants and Respondents.

APPEAL from a judgment of the Superior Court of Los Angeles County, Mitchell L. Beckloff, Judge. Affirmed.

Law Offices of Gregory G. Yacoubian and Gregory G. Yacoubian for Plaintiff and Appellant.

Hydee Feldstein Soto, City Attorney, Denise C. Mills, Chief Deputy City Attorney, Kathleen A. Kenealy, Chief Assistant City Attorney, Shaun Dabby Jacobs, Assistant City Attorney and Brian Cheng, Deputy City Attorney, for Defendants and Respondents. _________________________ Barbara Riggs was a sergeant with the Los Angeles Police Department at the onset of the COVID-19 pandemic. In 2021, the City of Los Angeles issued a mandatory COVID-19 vaccination policy requiring all City employees to vaccinate against the virus or request a medical or religious exemption. The City required employees who had requested an exemption to sign a notice acknowledging they were required to submit to twice-weekly COVID-19 testing with the City’s vendor at the employees’ expense ($65 per test) while their requests were pending. The City would reimburse those employees whose exemptions were granted. Riggs refused to sign the notice. She objected to paying for the testing and testing under the City’s vendor’s terms— which required her to agree that her sample and information could be shared for industry research and telemedicine purposes. Riggs was removed from duty pending a Board of Rights hearing. After the Board found Riggs guilty of failing to comply with the City’s COVID-19 vaccination and testing requirements— a condition of her employment—the Chief of Police discharged her. Riggs filed a petition for writ of mandate seeking back pay and reinstatement of her job. The trial court granted the petition in part, finding Riggs’s Skelly1 rights were violated and awarding her only back pay and benefits. On appeal, Riggs contends the City’s requirement that she pay the City for her testing violated Labor Code section 2802, the notice thus was void under section 2804, and she was entitled to reinstatement. We affirm.

1 Skelly v. State Personnel Board (1975) 15 Cal.3d 194, 215 (Skelly) (public employers must afford public employees due process before taking disciplinary action).

2 BACKGROUND 1. The City’s vaccination requirements In August 2021, the City adopted Ordinance 187134 requiring that all present and future employees, by October 19, 2021, become vaccinated against COVID-19—or request an exemption for religious or medical reasons—“[t]o protect the City’s workforce and the public that it serves.” The ordinance stated, “Employees with medical conditions/restrictions or sincerely held religious beliefs, practices, or observances that prevent them from receiving a COVID-19 vaccine shall qualify for COVID-19 vaccine exemption, upon approval of documentation provided by the employee to the appointing authority or designee.” Exempted employees were subject to weekly testing “at no cost during their work hours.” The ordinance included an urgency clause declaring “this ordinance is required for the immediate protection of the public peace, health, and safety.” The City then negotiated with its labor organizations— including Riggs’s union, the Los Angeles Police Protective League (LAPPL)—about the consequences of noncompliance with the ordinance. After reaching an impasse, the City issued its “Last, Best, and Final Offer” (LBFO) on October 14, 2021. The LBFO stated employees were noncompliant with the ordinance’s vaccination mandate “if they have failed to become fully vaccinated and have not filed an intent to seek a medical or religious exemption by October 20, 2021.” Such employees would be issued “a Notice of Mandatory COVID-19 Vaccination Policy Requirements” instructing them to submit proof of full vaccination by December 18, 2021. “Failure to sign or comply with the requirements of the Notice shall constitute failure

3 to meet a condition of employment and shall result in appropriate and immediate corrective action.” Employees who filed an intent to seek an exemption by October 20, 2021, however, would be considered “compliant with the Ordinance during the pendency of the exemption and accommodation process.” The LBFO continued: “Accordingly, the City shall not issue the Notice and/or take employment action against an employee who is duly subject to the exemption and accommodation procedures. [¶] Employees who have reported a vaccination status of ‘not vaccinated’ and who file exemption paperwork and are awaiting the result of the City’s evaluation process shall be subject to the same terms applicable to employees who are not fully vaccinated and who have received a Notice, including and limited to items 2, 3, 4, and 5.” Items 2, 3, 4, and 5 required the employee to test for COVID-19 twice per week, through the City’s vendor and on the employee’s own time, and to reimburse the City $260 per pay period for four tests —at $65 each—through biweekly payroll deductions. The LBFO then stated, “Each employee who is required to test while awaiting the determination by the City of their exemption request shall be required to sign a Notice and to comply with its terms . . . . Failure to sign and fulfill the conditions of the Notice shall constitute failure to meet a condition of employment and shall result in appropriate and immediate corrective action. [¶] If an employee who reported a vaccination status of ‘not vaccinated’ and who filed for an exemption is ultimately granted that exemption by the City, then the City shall reimburse the employee for the costs for testing.”

4 On October 26, 2021, the City Council passed a “Resolution Implementing Consequences for Non-compliance with the . . . Ordinance . . .” providing for immediate implementation of the LBFO. A stated basis of the resolution was the “significant financial burden” to the City if it “had to provide a weekly testing option for all unvaccinated City employees, or place all unvaccinated City employees on paid leave, while simultaneously paying overtime to cover staffing shortages resulting from their absence.” On October 28, 2021, the City’s mayor issued a memorandum to all City department heads—including the Chief of Police—directing that they “[i]mmediately implement” the LBFO. As relevant here, the mayor directed the department heads to “[i]ssue a Notice of Mandatory COVID-19 Vaccination Policy Requirements – While Awaiting an Exemption/Appeal Determination to each employee who is unvaccinated and has filed an exemption form.” (Footnote omitted.) If the employee refused to sign the notice, the employee was to follow the testing regimen outlined in the LBFO and was to “test on paid time and at City expense, except that the City” would “issue an invoice for the cost of testing.” The mayor also directed that department heads “immediately begin the corrective action process outlined in the LBFO” for each employee who remained noncompliant as of December 18, 2021. The memorandum stated: “An employee that remains out of compliance shall be placed off duty without pay pending service of a Skelly package that includes a Notice of Proposed Separation. Sworn employees shall be subject to applicable Board of Rights proceedings.”

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Riggs v. City of Los Angeles CA2/3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/riggs-v-city-of-los-angeles-ca23-calctapp-2025.