The type of administrative appeal is not clearly definitive by POBAR and is subject to dispute. An officer wishing to appeal a punitive action must take advantage of existing administrative avenues. Such appeal must follow the standards of fair play and due process. An officer may also be entitled to a prediscipline notice and opportunity to respond to the charges required by constitutional due process. Such a prediscipline due process right to respond in state service is known as a skelly hearing, named after a California court case. An officer should always contact his or her union and/or appropriate counsel.
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