ALADS v. Superior Court: Who Can Settle a County Employee’s Discharge Appeal?

If sheriff’s department chiefs sign a settlement reinstating a fired deputy while a civil service appeal is pending, the deal binds Los Angeles County only if the chiefs acted under authority from the board of supervisors or authority conferred by law. These deputies never showed that authority, so the county could refuse to honor their settlements.

That is the result in Association for Los Angeles Deputy Sheriffs v. Superior Court, No. B350110 (Cal. Ct. App. Oct. 30, 2026), from the Second Appellate District, Division One. The governing rule is a state statute, but the court’s reasons for finding no authority came from Los Angeles County’s charter, civil service rules and code.

Three Fired Deputies, Three Settlements and a County That Refused

David Jouzi, Benjamin Alvarado and Dellanira Aragon were sheriff’s deputies who, according to their pleading, received notices of intent to discharge in about 2017 and were fired for alleged misconduct after Skelly hearings. Each appealed to the county Civil Service Commission. In 2019, while the appeals were pending, each signed a settlement with a department chief that purported to reduce the discipline and reinstate them. They alleged the chiefs followed the department manual’s settlement procedure. The county refused to comply; it said the board of supervisors never approved the settlements, and the petitioners did not dispute that.

The deputies and their union, the Association for Los Angeles Deputy Sheriffs (ALADS), sued to enforce the deals. After a 2023 appeal (ALADS I) gave them a chance to plead the chiefs’ authority, and four amended pleadings later, the trial court sustained the county’s demurrer without leave to amend.

The statute is Government Code section 23005: “A county may exercise its powers only through the board of supervisors or through agents and officers acting under authority of the board or authority conferred by law.” The settlements, and with them the contract and mandamus claims, stood or fell on whether the chiefs had that authority. The court rejected all four of the petitioners’ arguments.

The Power to Fire Did Not Include the Power to Undo a Firing on Appeal

The lead argument was intuitive: the sheriff appoints, suspends and fires, and can delegate discipline, so the power to reverse discipline must come with it. “We acknowledge the facial appeal of petitioners’ position,” the court wrote, noting that one would expect such an official to be able to reverse the discipline and spare the county the cost of litigating the appeal.

The court still rejected it because of how the civil service system divides power. The sheriff appoints from an eligible list; the director of personnel keeps that list and can withhold names for conduct not compatible with the job; the commission hears appeals. If department officials could rescind a discharge mid-appeal without board consent, they could bypass the limits on rehiring people whose conduct is not compatible with county employment. Pointing to a 2020 trial-court ruling that blocked a newly elected sheriff’s attempt to reinstate a deputy fired under a prior sheriff, the court said accepting the petitioners’ view “would increase the risk of corruption and favoritism the civil service system was designed to avert.”

Money mattered too. Jouzi’s settlement appeared to provide back pay, yet a county ordinance lets county counsel settle claims without board approval only up to $20,000. The court would not infer that the board silently let department officials incur larger obligations.

The Manual, the Past Practice and an Earlier ALADS Win Did Not Supply Authority

The manual. The provision says the division chief or director “shall consult with a constitutional policing advisor and then obtain concurrence from the Undersheriff prior to entering into a settlement agreement.” The petitioners relied on a 2018 labor agreement to adopt it and a county code provision making such agreements binding when management signs. But that provision covers only matters within management’s “exclusive jurisdiction” or delegated by the board, and they identified neither a law nor a board delegation reaching commission settlements.

The past practice. The petitioners alleged that captains and chiefs had settled discipline appeals without board approval since at least 1980, and implied that the Meyers-Milias-Brown Act required the county to bargain before ending that practice. They never argued that ending it would significantly and adversely affect wages, hours or working conditions, the threshold for that duty, or addressed whether ending it was a fundamental managerial decision. So they failed to show the Act barred the county from abandoning it, and the court did not decide whether they adequately alleged the practice.

The earlier win. A 2013 unpublished decision had enforced a 1991 ALADS settlement about administrative interviews of deputies under criminal investigation. It decided a different issue, so it did not bar the county from contesting these settlements.

The Result

Promissory estoppel failed because it cannot override the public’s interest in limiting who may incur liability for the county. Any error on the declaratory relief claim was harmless because the claim beneath it failed, and the petitioners forfeited any challenge to the denial of leave to amend.

Because a July 2025 dismissal order and a later August judgment may have misled the petitioners about when to appeal, the court treated their possibly late appeal as a writ petition. The disposition: petition denied, with costs to the county and the other real parties in interest.

What to Check Before You Sign a Discipline Settlement

In our reading, a manager’s signature does not prove a public employer’s authority, and an internal manual or long habit of informal deals may not supply it. Before you sign a discipline settlement, ask:

• Who can bind this employer? Ask which board approval, ordinance, resolution or written delegation covers the settlement, and get a copy.
• Does money change the answer? Back pay may need separate approval; here the court pointed to the $20,000 cap on county counsel’s settlement authority.
• Is approval a condition? If so, the agreement should state it; be cautious about withdrawing a pending civil service appeal before someone with authority approves the deal.

Section 23005 applies to every county, but who can approve a settlement turns on what the board of supervisors has delegated and what other law authorizes, under each county’s ordinances and any charter; cities have their own rules.