The California Supreme Court issued an order on Jan. 21 modifying its November 2025 opinion in Los Angeles Police Protective League v. City of Los Angeles, making key corrections to the timeline of events involving a federal consent decree that affected police complaint procedures in Los Angeles.
The court's order addressed two specific passages in the original opinion that incorrectly suggested the City of Los Angeles entered into a federal consent decree after certain court decisions were made. The modifications clarify that the city actually entered the consent decree before those judicial rulings.
In the first correction, the court deleted a sentence that began "In the wake of those decisions" and replaced it with language stating that "Prior to the issuance of those decisions, the City of Los Angeles (the City) had entered into a consent decree with the federal government that effectively barred it from requiring complainants to sign the type of advisory described in section 148.6(a)(2)."
The second modification involved deleting a sentence beginning "Following those federal decisions" and replacing it with: "Before those cases were decided, the City had entered into a consent decree with the federal government that prevented the City from enforcing the advisory requirement set forth in section 148.6(a)(2)."
The case centers on Penal Code section 148.6(a)(2), which relates to requirements for advisories that complainants must receive when filing police misconduct complaints. The federal consent decree at issue prevented Los Angeles from enforcing these advisory requirements, creating a conflict between state law and federal oversight.
The Los Angeles Police Protective League, which represents LAPD officers, brought the case as plaintiff against the City of Los Angeles and other defendants. The case worked its way through the Los Angeles County Superior Court system before reaching the Second Appellate District, Division Seven, and ultimately the California Supreme Court.
The original opinion was authored by Justice Groban and joined by Chief Justice Guerrero and Justices Corrigan, Kruger, Evans, and Jenkins. The November 2025 decision appeared in volume 18 of the California Reports, Fifth Series, at page 970.
While the court made these factual corrections about timing, it emphasized that the modifications do not affect the underlying judgment in the case. This suggests that despite the timeline corrections, the legal conclusions and outcome of the case remain unchanged.
The court also denied a petition for rehearing, indicating that no party will get another opportunity to argue the case before the state's highest court. This denial finalizes the California Supreme Court's involvement in the matter.
The case highlights ongoing tensions between federal oversight of police departments and state law requirements. Federal consent decrees are often imposed on police departments following investigations into patterns of misconduct or constitutional violations. These decrees typically require departments to implement specific reforms and can override conflicting state or local requirements.
In Los Angeles, the federal consent decree mentioned in the case likely stems from the long history of federal oversight of the LAPD, which has been subject to various forms of federal monitoring and reform requirements over the years. The decree's prohibition on enforcing certain advisory requirements under state law demonstrates how federal oversight can create conflicts with existing state statutes.
The Police Protective League's victory in this case suggests the court found merit in the union's arguments about how the federal consent decree affected the city's obligations under state law. Police unions often challenge city policies that they believe violate officers' rights or exceed municipal authority.
The timing corrections made by the court are significant because they clarify the sequence of events that led to the legal dispute. By establishing that the federal consent decree preceded rather than followed certain court decisions, the modifications help clarify the legal landscape that existed when the underlying issues arose.
For practitioners in police law and municipal government, this case provides important guidance on how federal consent decrees interact with state statutory requirements. The decision also illustrates the California Supreme Court's willingness to correct factual errors in its opinions when brought to its attention.
The case number S275272 in the California Supreme Court corresponds to appellate case B306321 from the Second District and trial court case BC676283 from Los Angeles County Superior Court, showing the case's progression through the state court system.
With the petition for rehearing denied and the modifications complete, the case now stands as final precedent on the issues addressed, providing clarity for similar disputes that may arise between federal oversight requirements and state law mandates in police accountability matters.