The First Appellate District reversed a judgment and remanded the action with directions. The court held that a three-day-per-month mandatory unpaid furlough program for California state employees imposed by executive order of the Governor and ratified by the Legislature was valid as to state agencies and departments named in an “item of appropriation” in the pertinent legislative budget act.
In 2008, the California Governor issued an executive order in the face of projected, immense General Fund deficits for the 2008-2009 fiscal year. The executive order directed the Department of Personnel Administration to adopt a plan to furlough state employees for two days per month. In 2009, a subsequent executive order expanded the furlough program to three days per month.
