Can a police officer who has completed his probationary period be disciplined under section 3304(d) of the California Public Prosecutions Act?

proposed disciplinary action within one year of discovering the alleged misconduct. The notice contemplated by section 3304(d) is simply notice that the public agency, having completed its investigation, has decided that it may pursue disciplinary action against the officer. Although the agency is not precluded from notifying the officer at that time of the proposed specific discipline, it is not required by section 3304(d) to do so. Mays v. City of Los Angeles . . . (2008) 43 Cal.4th 313, 320-322.

"Finally, section 3304(f) provides that, where an agency decides to impose discipline after a predisciplinary investigation, it shall notify the officer in writing of its decision to impose discipline, including the date the discipline will be imposed, within 30 days unless the officer is unavailable for notice. The notice given in section 3304(f), unlike section 3304(d)'s informal notice of prospective discipline, is a formal notice of the discipline the agency intends to impose. Sulier v. State Personnel Board (2004) 125 Cal.App.4th 21, 29.

"Police officers who have completed their probationary period and are permanent employees have a property interest for purposes of due process with respect to their job and compensation. In addition to satisfying POBRA, a public entity must accord the police officer constitutional procedural due process before depriving the officer of this property interest. Charter 1070(a); see Skelly v. State Personnel Board (1975) 15 Cal.3d 194, 215. [] . . . []