Tipton-Whittingham v. City of Los Angeles Consent Decree Providing Injunctive Relief

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BARRETT S. LITT (SBN 45527)
ANNA Y. PARK (SBN 164242)
LAW OFFICE OF LITT & MARQUEZ 

A LAW CORPORATION 
3435 Wilshire Boulevard, Suite 1100 
Los Angeles, California 90010-1912 
(213) 386-3114

CONSTANCE L. RICE (SBN 153372) 
BILL LANN LEE (SBN 108452)
DARCI BURRELL (SBN 180467) 
NAACP LEGAL DEFENSE AND 

EDUCATIONAL FUND, IN C  
315 West Ninth Street, Suite 208 
Los Angeles, California 90015 
(213) 624-2405

CAROL A. SOBEL (SBN 84483)
MARK D. ROSENBAUM (SBN 59940) 
JO N  W. DAVIDSON (SBN 89301) 
SILVIA R. ARGUETA (SBN 144400) 
ACLU FOUNDATION OF 

SOUTHERN CALIFORNIA 
1616 Beverly Boulevard 
Los Angeles, California 90026 
(213) 977-9500

Attorneys for Plaintiffs
TERRY TIPTON-WHITTINGHAM, et al.

JAM ES K. HAHN, City Attorney 
FREDERICK N. MERKIN,

Senior Assistant City' Attorney 
CHARLES E. DICKERSON, 111,

Assistant City Attorney 
ROBERT CRAMER,

Assistant City Attorney (SBN 56805) 
1800 City Hall East 
200 North Main Street 
Los Angeles, California 90012-4131 
(213) 485-5432 FAX: (213) 485-8898

Attorneys for Defendants 
CITY OF LOS ANGELES, etal.

UNITED STATES D ISTRIC T COURT 

CENTRAL D ISTRIC T OF CALIFORNIA

TERRY TIPTON-W HITTINGHAM , )
et al., )

)
Plaintiffs, )

)
v.   )

)
CITY OF LOS ANGELES, et a l ,  )

)
Defendants. ) 
_____________)

CASE NO. CV 94-3240 (RC)

CONSENT DECREE PROVIDING 
INJUNCTIVE RELIEF

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I. PLAINTIFFS' CLAIM S AND THE PARTIES' DESIRE TO  RESOLVE THE CASE.

1. The plaintiffs in this action allege that defendants have engaged in an unlawful 

pattern of discrimination, harassment and retaliation on the basis of sex and race in violation 

of Title VI and Title VII, 42 U.S.C. §§ 2000d and 2000e, 42 U.S.C. §§ 1981 and 1983, and the 

California Fair Employment and Housing Act, California Government Code §§ 12940, et seq., 

among other statutes; and that a hostile work environment within the meaning of those 

statutes exists within the Los Angeles Police Department.

2. The parties seek to avoid the delay and uncertainty in achieving their goals 

which exist in adversary litigation.

3. This Consent Decree is the product of extensive negotiation between the 

plaintiffs and the defendants. By entering into this Consent Decree, defendants do not admit 

any wrongdoing and continue to expressly deny each and every allegation of the complaint.

4. Nothing in this Consent Decree shall be deemed to constitute an admission of 

liability, nor may this Consent Decree be used as evidence of liability in any court or 

proceeding.

5. It is, therefore, mutually agreed by and between the parties to this Consent 

Decree, and THE COURT ORDERS, as follows:

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II. STIPULATION TO AND DEFINITION OF THE CLASS.

1. The parties stipulate to the following class for purposes of this Consent Decree 

but for no other purpose.

a) all present and future women and minority employees of, or applicants 

to, the Los Angeles Police Department, sworn and unsworn, and

b) all present and future employees of the Los Angeles Police Department, 

sworn and unsworn, who have been, are presently, or will be subject to 

retaliation for making complaints of, or expressing opposition to, 

unlawful discrimination on the basis of sex, race, ethnicity, or a 

combination of sex and race or ethnicity.

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III. GOALS AND OBJECTIVES OF THE CONSENT DECREE

1. It is the continuing desire of the parties and the policy of the City of Los Angeles 

to provide equal employment opportunity for all City and Los Angeles Police Department 

employees and to provide a working environment free from all unlawful discrimination.

2. The parties hereby stipulate the terms and conditions governing intermediate 

level promotions, paygrade advancements, and coveted positions set forth in the August 27, 

1992 Consent Decree in John W. Hunter v. City o f  Los Angeles, No. CV-92-1897-AWT (Central 

Dist., Cal.) and Latin American Law Enforcement Association v. City o f  Los Angeles, No. CV-92- 

1898-AWT (Central Dist., Cal.) [hereafter referred to as “Hunter/LaLei/"], as modified by the 

parties or the Court, shall apply to all sworn intermediate level female employees of the 

Department consistent with prior City Council Resolutions. A copy of the Hunter/LaLey 

Consent Decree is attached hereto as Exhibit 1 and its terms are incorporated by reference as if 

set forth fully herein.

3. The parties desire to ensure, to the extent feasible, that the monitoring functions 

called for in Hunter/LaLey and in this Consent Decree be coordinated.

4. The parties seek standards relating to recruitment and outreach, appointment, 

and Police Academy training and probationary training, in order to address any 

underrepresentation of, and to remove any unlawful impediment facing, women and 

minority applicants, recruits, and probationary officers.

5. Nothing in this Consent Decree is intended by the parties to compel the City to 

violate any requirement imposed by the California Commission on Peace Officer Standards 

and Training.

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6. The parties seek standards narrowly tailored to address any 

underrepresentation of, and to remove any unlawful impediments to, female and minority 

sworn employees seeking to achieve (a) promotions to the classifications of Police Detective, 

Police Sergeant, and Police Lieutenant, (b) advancements to the paygrades of Police Officer II, 

Sergeant III, Detective II, Detective III, and Lieutenant II, and (c) assignments to coveted 

positions as defined herein. This includes seeking Department standards to prevent any 

impediments to the advancement and job mobility of bilingual officers who are required to 

use a language other than English on the job. The fact that an officer receiving a bilingual pay 

bonus must forego that bonus to advance to a position not requiring the officer's bilingual 

skills is not an impediment to advancement or job mobility. The parties seek to accomplish 

these objectives without affecting the legitimate rights and privileges of other Department 

employees.

7. The parties seek standards narrowly tailored to address any

underrepresentation of, and to remove any unlawful impediments to, female and minority 

non-sworn personnel within the Department.

8. The parties seek standards to eliminate all unlawful harassment in the 

workplace.

9. The parties seek to promote and effectuate the purposes of Title VI and Title VII, 

42 U.S.C. §§ 2000d and 2000e, 42 U.S.C. §§ 1981 and 1983, the Fair Employment and Housing 

Act, and California Government Code §§ 12940, et seq. by augmenting existing programs, 

policies, and procedures.

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10. None of the goals, interim goals, or goal attainment procedures which may be 

developed under this Consent Decree shall be utilized as quotas. This Consent Decree shall 

not be construed to require or to permit the use of quota relief, or to require or to permit the 

hiring, promotion, pay grade advancement, or assignment of any unqualified person.

IV. DEFINITIONS.

1. The term "promotion," as used in this Consent Decree, means promotion to the 

civil service classifications of Police Detective, Police Sergeant, and Police Lieutenant.

2. The term "paygrade advancement," as used in this Consent Decree, means 

advancement to the Police Officer III, Detective II, Detective III, Sergeant II, and Lieutenant II 

paygrades.



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3. The term "coveted position," as used in this Consent Decree, means those 

Department sworn police officer assignments likely to assist an officer in developing the 

insight and skills necessary to enhance a career path of promotability toward the command 

and staff ranks. For purposes of this Consent Decree only, "coveted position" shall include at 

least the following: (i) all Lieutenant I and Lieutenant II staff positions at the Office or Bureau 

level; (ii) all Lieutenant II unit officer-in-charge positions; (iii) all Lieutenant II division 

commanding officer positions; (iv) all Sergeant I and II staff positions at the Office or Bureau 

level; (v) all Sergeant n Geographic Area vice unit positions; (vi) all Sergeant II Geographic 

Area assistant watch commander positions; (vii) all Sergeant II Internal Affairs Division 

positions; (viii) all Sergeant II Planning and Research Division positions; (i-x) all Sergeant II 

unit officer-in-charge positions; (x) all Sergeant I patrol adjutant positions; (xi) all Police 

Officer III and Police Officer III+l staff positions at the Office or Bureau level; (xii) all Police 

Officer III+l Internal Affairs Division positions; (xiii) all Police Officer III+l Geographic Area 

positions; (xiv) all Police Officer III staff researcher and writer positions; (xv) all Detective II 

and Detective III positions assigned to the Office of Chief of Police; and (xvi) all Detective II 

and Detective III positions assigned to the front and back offices at a Bureau or Office level.

4. The term "minority" or reference to groups "of color," as used in this Consent 

Decree, apply to African Americans, Hispanics, and Asian Americans (including Asian 

Americans, Pacific Islanders and Filipinos).

5. The terms "gender," "gender-based," "sex," or "sexual" are interchangeable and 

do not have separate meanings. The terms "female" or "women" or "woman," unless stated 

otherwise, include women of color.

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6. The terms "unlawful harassment" or "unlawful discrimination," or the same 

terms without the word "unlawful" before them, refer to such conduct on the basis of sex, 

sexual orientation, race and/or ethnicity and include the concept of a "hostile work 

environment," unless otherwise limited or expanded by the context. The terms "unlawful 

discrimination" or "discrimination" include harassment and retaliation for past complaints of 

discrimination or harassment as defined under Title VII and FEHA.

7. The terms "Department" or "LAPD" mean the Los Angeles Police Department.

8. The term "City" refers to the City of Los Angeles. Wherever this Consent Decree 

imposes specified duties or obligations upon the City, the same specified duties or obligations 

apply to the Department or, where appropriate, to the Board of Police Commissioners, unless 

the Consent Decree expressly indicates otherwise.

9. Whenever the term "will" or "shall" is used in this Consent Decree in connection 

with an obligation of the City or the Department, no inference exists that the City or 

Department was not already implementing the obligation, or any of the standards required by 

this Consent Decree.

10. The term "entity" as used in this Consent Decree refers to any level of 

organization within the Department, depending on the context in which it is used.

11. The term "notice" is broadly defined to include City bulletins, Departmental 

advertisements, Departmental bulletins, and any other means by which promotional, 

advancement or assignment opportunities are announced.



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12. The term "underrepresentation," when used in this Consent Decree to refer to 

entry level positions, means the representation of women or a particular minority group at a 

lower level than the group's proportion in the civilian labor force of the County of Los 

Angeles.

13. The term "underrepresentation," when used in this Consent Decree to refer to 

nonentry level positions, means the representation of women or a particular minority group at 

a lower level than the group's proportion in the pool of persons with sufficient time in those 

job classifications or paygrade levels that qualify them for promotion, appointment, 

advancement, or assignment to the particular position.

14. The term "standards" as used in this Consent Decree has a broad meaning, and 

encompasses formal and informal procedures, practices, guidelines, policies, mechanisms and 

plans.

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V. SPECIFIC ACTIONS TO  BE TAKEN BY THE CITY.

1. The City will prepare, conduct and evaluate an "Attitude" survey of all 

Department employees within six months of entry of this Consent Decree. The purpose of the 

survey will be to determine any impediments, problems or barriers to full employment 

opportunities within the Department. A priority objective of the survey will be to determine 

the existence of any impediments, problems or barriers to full employment opportunities for 

women and minorities within the Department. Survey participants will be identified by race 

and/or ethnicity, and sex. Any perceptions of impediments, problems or barriers to full 

employment opportunities will be evaluated from the perspective of the sub-groups who 

express those perceptions. The survey will include the participants' observations regarding 

whether they have experienced formal or informal barriers to applying for or obtaining 

promotions, paygrade advancements or coveted positions, and, if so, what those experiences 

have been.

2. Information and results of the survey conducted pursuant to this Consent 

Decree described in f  V (1) shall be for use in conjunction with this Consent Decree only. Such 

information and results shall remain confidential and shall not be used in any other matter, or 

distributed to any person other than for use in connection with this Consent Decree.

3. The City will identify all applications within the fiscal years ending June 30, 

1994-1996, by sworn employees for promotion to the classification of Police Lieutenant or 

below, for paygrade advancement to the position of Lieutenant II or below, or for assignment 

to a coveted position, and the outcome of each such application. Each applicant will be 

identified by race or ethnicity and gender. Coveted position data will reflect the eligible, 

rather than actual, applicants.

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4 . The City and the Department will annually identify the racial/ethnic and gender 

composition of all entities composed of 8 or more people. To the extent that this information is 

currently available electronically, or through already compiled data, a report covering the past 

three years will also be prepared.

5. The City will identify, evaluate, and include any and all special requirements for 

a particular promotional, paygrade advancement, or coveted position opportunity in the 

notice of the position. The notice announcing the position shall include identification of the 

primary areas of knowledge required for each level of promotion, paygrade advancement 

and/or coveted position, and any specialized knowledge required for a particular position 

because of geographic or other unique characteristics.

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6. The City and the Department will prepare annual recruitment and outreach 

plans (hereafter "plans") for women and for each minority group. Each recruitment plan shall 

include (a) a comparison of the prior year's recruitment and the current Los Angeles County 

civilian labor force representation of the group; (b) an analysis of recent recruitment patterns, 

(c) an analysis of pertinent demographic trends, (d) an evaluation of recent recruitment, 

outreach activities, and resources expended, (e) an evaluation of prior annual plans, (f) an 

assessment whether the use of recruitment and outreach goals, benchmarks, timetables 

and/or other mechanisms are appropriate and necessary for the upcoming year, (g) a 

specification of any appropriate goals, benchmarks, timetables and/or other mechanisms, (h) 

an explanation of specific recruitment and outreach programs and activities planned for the 

upcoming year to assure maximum recruitment and outreach, (i) a description of resources 

and staffing for the recruitment effort planned for the upcoming year, (j) a tentative budget for 

the upcoming year to maximize recruitment efforts, and (k) an explanation of appropriate 

experts, officer groups and community groups consulted in the preparation of the plan. Each 

annual plan is to be prepared by the Department, in consultation with plaintiffs and the 

Department's women's and minority advisory committees, by May 31st of each year this 

Consent Decree is in effect. Each annual plan shall be implemented at the beginning of each 

fiscal year.

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7. Notwithstanding the provisions of f  V (6), appropriate and necessary annual 

recruitment goals for women may be established at levels lower than the representation of 

women in the Los Angeles County civilian labor force, provided that such goals represent 

periodic incremental increases toward the objective of hiring women sworn police officers in 

the fiscal year beginning 2013 in the same proportion as women then hold in the Los Angeles 

County civilian labor force. The goals set for women shall have internal goals that will reflect

each ethnic group's representation within the current civilian labor force, but, to the extent
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those minority^/goals cannot be met, the overall goal for women shall remain the same. The 

internal goals will be modified to reflect changes in the Los Angeles County civilian labor 

force.

8. The City and the Department will review, within one year after entry of this 

Consent Decree, all criteria and standards for recruitment, appointment, Academy training, 

probationary training, promotions, paygrade advancements, coveted positions, involuntary 

transfers, and performance evaluations to determine whether any criteria adversely affect the 

recruitment, selection or retention of women or any minority group. If it is determined that 

such criteria exist, the City will determine whether such criteria are job related. The City will 

eliminate any such non-job-related criteria, and, where adverse impact exists, will ensure that 

all questions and procedures have been properly validated in accordance with EEOC and 

DFEH guidelines. In addition, the standards set forth in <1 33 of the Hunter/LaLei/ Consent 

Decree will govern the conduct of any paygrade advancement and coveted position oral 

interviews. The City shall prepare a report to plaintiffs' counsel regarding the results of the 

review.

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9. The City will provide to plaintiffs' counsel, on an annual basis, a report of all 

applications for paygrade advancements, coveted positions and promotions, omitting any 

reference to applicants' names or personal identifiers, and organizing the results by race and 

gender.

10. The City will make a good faith, reasonable effort to provide gender and 

ethnicity balance on all recruitment teams, interview teams, Academy training staff and other 

personnel involved in recruitment, hiring, and training.

11. When the City is using outside raters, it will make a good faith, reasonable effort 

to identify and involve African Americans, Asian Americans, Hispanics and females on a 

consistent basis in promotional panels.

VI. ESTABLISHMENT OF A D ISCRIM IN ATION  OFFICE FOR THE ENFORCEMENT

OF ALL STANDARDS AND O BJECTIVES IDENTIFIED HEREIN.

1. As soon as possible but in no event more than six months after the effective date 

of this Consent Decree, the City shall establish a Discrimination Office under the authority of 

the Board of Police Commissioners to be responsible for all issues of discrimination within the 

Department. The Chair of the Discrimination Office shall have at least six additional 

nonclerical personnel assigned to the office, balanced between sworn and non-sworn 

personnel, and reflecting the gender, race and ethnic diversity of the Department to the extent 

practicable. The Discrimination Office shall have an officer assigned to it, and trained within 

it, of sufficient rank that recommendations regarding appropriate discipline to command staff 

will carry considerable weight.

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VII. CONTINUING ISSU ES UNDER THE CONSENT DECREE.

A. The Plaintiffs and Their Counsel.

1. It is the intent of the parties to this Consent Decree to harmonize the obligations 

under Hunter/LaLey and this case, but not supplant any Hunter/LaLei/ requirements. 

Accordingly, the parties stipulate to the intervention of the plaintiffs in Hunter/LaLeif on the 

injunctive relief claims in this case.

2. The term "plaintiffs" as used in this Consent Decree includes current plaintiffs in 

either Hunter/LaLexj or Tipton-Whittingham, or any plaintiffs added to either.

The term "plaintiffs' counsel," as used in this Consent Decree, refers to the following 

firms: NAACP Legal Defense & Educational Fund, Inc., the ACLU Foundation of Southern 

California, Lift & Mdrquez, the Mexican American Legal Defense and Educational Fund, and 

the Asian Pacific American Legal Center.

B. The Term, Monitoring And Enforcement O f The Consent Decree.

1. All reports provided for in this Consent Decree shall be supplied to plaintiffs.

After approval by counsel for the City, plaintiffs shall be provided with additional relevant 

information if they so request.

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2. Beginning within one year of the entry of this Consent Decree, and continuing 

throughout its term, the City shall maintain files organized by applicant and employee in 

computer readable form containing the following information: Name; badge number; 

computer identification number; date of birth; place of birth; educational level; sex, 

race/ethnicity; date of application; application tests given; application test scores; acceptance 

or rejection of application; reasons for application rejection; date of entry into Academy; 

Academy performance evaluation and/or test scores; Academy ranking; date failed to 

successfully complete Academy if failed; reason failed to successfully complete Academy if 

failed; date of graduation from Academy if graduated; each change of position, rank and title 

held, and the beginning and ending dates; each division worked at and the beginning and 

ending dates; each assignment to an entity containing eight (8) or more people and the 

beginning and ending dates; each paygrade advancement and the beginning and ending 

dates; each coveted assignment and the beginning and ending dates; each application for a 

pay-grade advancement, coveted position and/or promotion and the dates; the individual's 

test scores or other performance by ranking criteria utilized for determining the outcome of 

each application for a paygrade advancement, coveted position and/or promotion; outcome 

of the application for a paygrade advancement, coveted position and/or promotion; each 

administrative transfer, its date, and the reason for it. The computer readable files will be 

provided annually to plaintiffs, except that all names and badge numbers of any applicants or 

employees will be deleted. This data shall be treated as confidential, and plaintiffs and their 

counsel shall use it only in connection with this litigation. Plaintiffs may apply to the Court 

for access to the deleted information upon a showing of good cause.

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3. On any matters covered by this Consent Decree, the parties shall meet and 

confer at the request of either party to discuss those matters. No party to this action may seek 

Court relief or action under this Consent Decree unless the party first provides written notice 

of the alleged violation, or other ground for relief, to the other parties and goes through the 

meet and confer process

4. This Consent Decree shall have a term of 18 years unless sooner terminated or 

extended by the Court. The City may petition to be relieved of all or part of its obligations 

under the terms of this Consent Decree at any time upon a showing of accomplishment of all 

of the objectives of that portion of the Consent Decree from which the City seeks relief. This 

Court retains jurisdiction over this Consent Decree until such time as its term expires.

C. Issues Noi Addressed.

1. Issues not addressed by this Consent Decree, including claims for further 

injunctive relief, claims for damages, and claims for attorney's fees and costs, are reserved.

V III. SEVERABILITY.

1. In the event that any provision of this Consent Decree shall be determined by a 

Court to be invalid for any reason, that provision shall be severable from, and shall not affect 

the validity of, the remaining provisions. It is the intent of the parties that each of the 

provisions of this Consent Decree shall be enforceable independently of any of its other 

provisions.

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ORDER

GOOD CAUSE APPEARING, IT IS SO ORDERED.

Dated: November_____ , 1996
ROSALYN M. CHAPMAN
United States Magistrate ]udge

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AGREED AND ACCEPTED:

Dated: November , 1996 LITT & MARQUEZ

Dated: November , 1996

By:
BARRETT S. LITT

Attorneys for Plaintiffs

ACLU FOUNDATION 
OF SOUTHERN CALIFORNIA

Dated: November , 1996

By:
CAROL A. SOBEL

Attorneys for Plaintiffs

NAACP LEGAL DEFENSE AND 
EDUCATIONAL FUND, IN C

By:
CONSTANCE L. RICE

Attorneys far Plaintiffs and Plaintiff-Intervenor

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Dated: November_____ ,1996 MEXICAN AMERICAN LEGAL DEFENSE
AND EDUCATIONAL FUND

By; _______________________________ _________
THOM AS A. SAENZ

Attorneys for Plaintiff-lntervenor 
Lntin American Luo Enforcement Association

Dated: November_____ ,1996 ASIAN PACIFIC AMERICAN 
LEGAL CENTER

B y :_______________________________ _________
BONNIE TANG

Attorneys for Plaintiff-lntervenor 
Luo Enforcement Association o f  Asian Pacifies

Dated: November_____ , 1996 JAM ES K. HAHN, City Attorney
FREDERICK N. MERKIN,

Senior Assistant City Attorney 
CHARLES E. DICKERSON, III, 

Assistant City Attorney 
ROBERT CRAMER,

Assistant City Attorney

B y :______________________________
ROBERT CRAMER 

Assistant City Attorney 
Attorneys fo r  Defendants

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