The First Appellate District granted a petition for writ of mandate, holding that the Governor authority under Insurance Code §11873 to furlough employees of the State Compensation Insurance Fund.

Faced with a fiscal crisis in state government, in December 2008, Governor Schwarzenegger issued an executive order directing the Department of Personnel Administration (DPA) to formulate and adopt a plan for furloughing state employees and supervisors for two days per month, without regard to how their salaries were funded.