San Diego Police Officers' Assn. v. City of San Diego CA4/1

CourtCalifornia Court of Appeal
DecidedApril 8, 2026
DocketD084773
StatusUnpublished

This text of San Diego Police Officers' Assn. v. City of San Diego CA4/1 (San Diego Police Officers' Assn. v. City of San Diego CA4/1) 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.

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San Diego Police Officers' Assn. v. City of San Diego CA4/1, (Cal. Ct. App. 2026).

Opinion

Filed 4/8/26 San Diego Police Officers’ Assn. v. City of San Diego CA4/1

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

SAN DIEGO POLICE OFFICERS’ D084773 ASSOCIATION,

Plaintiff and Appellant, (Super. Ct. No. v. 37-2022-00031121-CU-WM-CTL)

CITY OF SAN DIEGO,

Defendant and Appellant.

APPEALS from a judgment of the Superior Court of San Diego County, Katherine A. Bacal, Judge. Affirmed.

Law Office of Michael A. Conger and Michael A. Conger for Plaintiff and Appellant. Heather Ferbert, City Attorney, M. Travis Phelps, Assistant City Attorney and Jana Mickova Will, Deputy City Attorney for Defendant and Appellant. The San Diego Police Officers’ Association (Association) sought a writ of mandate (Civ. Code, § 1085) and declaratory relief against the City of San Diego (City) in part seeking a judicial declaration that an element of compensation for police lieutenants and captains—police management incentive pay (incentive pay)—is pensionable, that is, included in “Base Compensation” as defined in section 24.0103 of the San Diego Municipal Code (SDMC 24.0103) for purposes of their pension calculations. Following a bench trial, the trial court ruled City properly determined the incentive pay was not pensionable. Association appeals, contending the court erred by failing to follow this court’s prior unpublished opinion in Sloan v. City of San Diego, D049158 (Jan. 29, 2008) (Sloan), which it says bars City from relitigating the issue. Association maintains the incentive pay is pensionable under certain City documents that memorialize excluded and included items of pensionable compensation (the “Earnings Codes Document”) because it is paid to captains and lieutenants for ordinary work hours at the same rate of pay. Association argues any ambiguity on the issue should have been resolved in favor of the employees claiming the right to the pension. Association further contends the court should have issued a writ of mandate requiring City to void its modification of what Association characterizes as “rules” for determining Base Compensation and to take steps to correctly report officers’ Base Compensation to City’s retirement system. Finally Association argues the trial court erred by failing to resolve its declaratory relief cause of action. City has also appealed from the judgment, arguing Association’s claims, particularly its argument that City had improperly changed the Earnings Codes Document “rules,” are either barred by the statute of limitations or by issue and claim preclusion. We affirm the judgment.

2 FACTUAL AND PROCEDURAL BACKGROUND The July 2021 MOU and Bargaining Association is the recognized collective bargaining group for City police officers. In July 2021, City and Association entered into a memorandum of understanding (the July 2021 MOU) providing that managerial employees,

captains and lieutenants, “will receive an annual $3,000 cash incentive pay.”1 During their bargaining negotiations, City and Association representatives did not discuss whether the incentive pay would be included in Base Compensation for purposes of determining retirement benefits. Association did not meet and confer over the issue. After the parties signed the MOU, City notified Association that though it had initially determined the incentive pay was pensionable, on further consideration it decided it was not. Association’s Action for Writ of Mandate and Declaratory Relief In 2022, Association filed an action seeking a writ of mandate requiring City to include the incentive pay in Base Compensation, which it acknowledged was defined in SDMC 24.0103. Association alleged that since July 2021, every City’s Earnings Codes Document had incorrectly excluded incentive pay from Base Compensation and final compensation, which affected employees’ retirement allowances. It sought a judicial declaration that (1) SDMC 24.0103, (2) City rules for determining which pay items are to be included in Base Compensation, or (3) constitutional protections afforded pension rights, or all three, required City to include the incentive pay in Base Compensation.

1 In full, Article 75 of the MOU provides: “Effective July 1, 2021, or the first full pay period following City Council approval of this MOU, whichever is later, in recognition of on-call and other operational responsibilities for Police Management positions (i.e., Police Lieutenant and higher), these employees will receive an annual $3,000 cash incentive pay.” 3 In 2023, Association amended its complaint to add a claim alleging that by unilaterally amending the Earnings Codes Document, City violated the Meyers-Milias-Brown Act (Gov. Code, § 3500 et seq.). Association asked the court to issue a peremptory writ of mandate voiding the unilateral modification, and requiring City to correctly report officers’ Base Compensation to the retirement system. Before trial, the court granted summary adjudication in City’s favor on Association’s Meyers-Milias-Brown Act claim, ruling Association had failed to exhaust its administrative remedies with the Public Employment Relations Board (PERB). Association’s Trial Brief and Evidence The matter proceeded to a three-day bench trial. Association’s theory was that whether incentive pay was pensionable was governed by SDMC 24.0103 and its definition of Base Compensation, which was interpreted by this court in Sloan, supra, D049158 to incorporate the City’s Earnings Codes Document and pensionability “rules.” According to Association, the Earnings Codes Document rules provided that a particular component of compensation is “ ‘included in retirement base earnings because all employees performing that class of work during their ordinary work hours on a consistent basis earn them at the same rate of pay.’ ” Thus, Association took the position that “[b]ecause management incentive pay is paid to all . . . captains and lieutenants for work during their ordinary work hours, management incentive pay is pensionable.” Association argued Sloan barred City from relitigating the issue under res judicata and collateral estoppel, even though after 2005, City had stopped publishing the so-called rules in its annual Earnings Codes Document.

4 Association presented evidence from its board members Jack Shaeffer and Jared Wilson, as well as attorney Bradley Fields, who helped negotiate the incentive pay which came into being in the July 2021 MOU. Shaeffer testified he signed the 2021 MOU. He confirmed that parts of it addressed whether various allowances were pensionable, and that Association and City had entered into side agreements on issues including uniforms and hiring of provisional employees. He testified that City never sent any notification about changing its Earnings Codes Document, and there were no side letters on the matter. Wilson, the then-current Association president, testified that Association negotiated incentive pay in fiscal year 2022, which began July 1, 2021, and ended June 30, 2022. He confirmed that all police captains and lieutenants, who were exempt from getting overtime pay, received incentive pay, which had nothing to do with hours worked, but was part of their normal pay. Fields testified that the pensionability of the incentive pay never came up in negotiations, and he did not agree with City’s position that it was not pensionable. He stated he did not respond to City’s e-mail about it because after City finalized its position, he had no ability to do anything but accept or litigate the issue.

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