When asserting the lawful, non–discriminatory, good faith personnel action defense to a psychiatric claim under LC §3208.3(h), consider the recent case of Ferrell v. County of Riverside, 81 CCC 943 where the Court stated that the term “personnel action” is not intended to cover all actions by any level of personnel or all happenings in workplace. But, it is instead to include conduct by management including, but not limited to, transfers, demotions, layoffs, and certain disciplinary actions.