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Blanco v. McLaughlin
California Highway Patrol (CHP) officer received a memorandum from a superior officer stating he had been observed participating in a Hell’s Angels sponsored event. The memorandum warned that the CHP might seek to impose discipline if he were to engage in similar activities in the future. Plaintiff claimed he was entitled to an administrative appeal and filed a petition for a writ of mandate in the trial court directing the CHP to afford him such an appeal to challenge the memorandum. The trial court granted the petition, finding that Plaintiff was entitled to an evidentiary hearing before a neutral finder of fact.
In this appeal, Appellants seek to overturn the trial court’s judgment, arguing that the memorandum did not constitute “punitive action” affording Plaintiff the right to seek an administrative appeal. Court agrees and, accordingly, reversed the judgment.

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