The First Appellate District reversed a judgment. The court held that a two-day-a-month unpaid furlough program for state employees that was instituted by the Governor did not violate California statutes.

On December 19, 2008, the Governor issued an executive order that directed the Department of Personnel Administration (DPA) to implement a furlough of represented state employees and supervisors for two days per month, regardless of funding source. The program was to be effective from February 1, 2009, through June 30, 2010.