La Verne

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La Verne Firefighters' Association Lawsuit

The La Verne Firefighters' Association, Local 3624 and numerous individuals have commenced litigation against the City of La Verne and its Fire Chief, Pete Jankowski. It seems that labor associations may often criticize public agencies and management in order to apply political, public, and media pressure in an attempt to further their agenda. The City of La Verne respects the rights of its individual employees and the litigation process, but also believes that providing factual information regarding this matter is equally as important. As such, the City will not be commenting on specific strategies, tactics, and defenses involved in this case.

This webpage will be used to host public documents that the City believes will keep you best informed.


  • On April 27, 2017, the City Manager and Personnel Officer hosted a morning meeting for and with the newly elected Fire Association Board officers. During this meeting, the City Manager offered to meet with the entire Fire Association membership together with the Fire Chief. That subsequent meeting was tentatively scheduled for May 10th. Later that afternoon, the Fire Association canceled the proposed May 10th meeting.
  • On May 8, 2017, the Fire Association generated a Letter of No Confidence regarding Fire Chief Jankowski. A copy of that letter can be viewed by clicking here: pdf Vote of No Confidence (80 KB) .
  • On May 10, 2017 the City Manager requested that the Fire Association meet with him, the Fire Chief, and Personnel Officer to discuss the letter. The Fire Association refused to meet if the Fire Chief was going to attend the meeting.
  • On May 28, 2017 the City Manager agreed to meet with the Fire Association without the Fire Chief in attendance and requested date and time options from the Fire Association.
  • On June 8, 2017, the City received a cease and desist letter on behalf of the Fire Association with further instructions from the Fire Association's legal counsel. A copy of that letter can be viewed by clicking here  pdf LVFA Cease and Desist (511 KB) .
  • On June 13, 2017, the City contacted the Fire Association's legal counsel and attempted to schedule a meeting with Association personnel.
  • On August 21, 2017, the City received a tort claim on behalf of, among others, the Fire Association. A copy of that tort claim can be viewed by clicking here:  pdf LVFA Retaliation Claim (969 KB) .
  • On October 30, 2017, legal counsel for the Fire Association met with the City Manager and City Attorney. No Fire Association members attended the meeting. Legal counsel for the Fire Association requested that the City agree to (a) pay monetary damages and (b) terminate Fire Chief Jankowski. Fire Association legal counsel indicated that no meeting with their clients would be permitted.
  • On December 5, 2017, the City received notice of the litigation filed against it and Chief Jankowski. A copy of that lawsuit can be viewed by clicking here: pdf Firefighters Complaint (180 KB) .
  • On February 22, 2018, the City received an amended lawsuit from the La Verne Firefighters Association. A copy of the amended lawsuit can be viewed by clicking here: pdf 2a (Dkt 18) Montoya FAC 022118 (388 KB) .
  • On February 27, 2018, the city was served an additional lawsuit from individual members of the La Verne Firefighters Association. A copy of the additional lawsuit can be viewed by clicking here: pdf 2018 02 27 US District Court Summons in a Civil Action (6.12 MB) .
  • On March 15, 2018, the City's legal counsel filed what is called an Answer to the plaintiffs' amended complaint. The city continues to maintain that there was no wrongdoing by it or anyone acting on its behalf. The City's pleading also includes what are called Affirmative Defenses. Affirmative Defenses are asserted by the City's legal counsel and may, eventually, help to defeat or mitigate the allegations of the plaintiffs. A copy of the Answer can be viewed by clicking here: pdf 20180315 Montoya DeftsAnswer FAC 1969117 (465 KB) .

Additionally, it has been brought to the City's attention that the Fire Association is holding meetings posing a variety of questions.  Following is the City's factual response on some of those so you have context and accurate information.

Does Fire Station 3 have a fire engine? No. There has never been a fully-staffed fire engine at that location. The station was originally opened in 2007 and staffed with two employees classified as firefighter/paramedics. There was a time when the USDA Forest Service rented space and housed one of the Forest Service's wildland fire engines and a crew at the station. But, that ended in 2013. Periodically, you might have also seen some of the City's reserve fire apparatus stored there.

Has the City eliminated one engineer/paramedic assignment? Yes. Staffing of the ambulance at Fire Station 3 will change from one engineer/paramedic and one firefighter/paramedic to two firefighter/paramedics. The City's overall engineer rank will decrease from 9 to 6 total personnel while the firefighter/paramedic rank numbers will increase from 15 to 18 positions. All La Verne Fire Department units will remain at current staffing and the number of fire department sworn personnel will remain unchanged at 34 employees.

Is the City having serious Fire Department personnel retention issues? No.  Since January 2013, only two firefighter/paramedic employees have left the City. 

As to the La Verne Firefighters Association's vote, you can find the actual document here: pdf Vote of No Confidence (80 KB) .

The City, of course, will keep providing the high level of services everyone has come to enjoy, and City staff will continue to make La Verne the special place for which it is known.

Please continue to check back on this page for official, up-to-date information and source materials as well as information on the City's further response to this litigation.