Bryan R. Berry


This Note examines DiRuzza v. County of Tehama, a recent Ninth Circuit decision that takes a case-specific approach to defining the position of deputy sheriff for the purpose of deciding whether that position involves policymaking and is, therefore, subject to patronage. Furthermore, this Note reviews the landscape of other circuit court decisions on the susceptibility of deputy sheriffs to patronage termination, including the Eighth Circuit’s relative silence on the issue. Finally, this Note argues that the Supreme Court should sanction the approach espoused by DiRuzza in an effort to harmonize what has become cacophonous mix of low court voices on the issue of patronage.

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