Ayers v. Currituck Cty. Dep't of Soc. Servs.

CourtCourt of Appeals of North Carolina
DecidedOctober 5, 2021
Docket20-464
StatusPublished

This text of Ayers v. Currituck Cty. Dep't of Soc. Servs. (Ayers v. Currituck Cty. Dep't of Soc. Servs.) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ayers v. Currituck Cty. Dep't of Soc. Servs., (N.C. Ct. App. 2021).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2021-NCCOA-521

No. COA20-464

Filed 5 October 2021

Office of Administrative Hearings, No. 17 OSP 08518

JUDITH M. AYERS, Petitioner,

v.

CURRITUCK COUNTY DEPARTMENT OF SOCIAL SERVICES, Respondent.

Appeal by Respondent from final decision entered 5 May 2020 by

Administrative Law Judge Melissa Owens Lassiter in the Office of Administrative

Hearings. Heard in the Court of Appeals 23 March 2021.

Hornthal, Riley, Ellis, & Maland, L.L.P., by John D. Leidy, for petitioner- appellee.

The Twiford Law Firm, P.C., by John S. Morrison, for respondent-appellant.

MURPHY, Judge.

¶1 When a party challenges findings of fact and conclusions of law in an

administrative law judge’s (“ALJ”) order reviewing discipline of a career State

employee, we conduct a whole record test to determine whether substantial evidence

supported the findings of fact and review the challenged conclusions of law de novo.

When determining whether an agency had just cause for the disciplinary action taken

against a career State employee, we must evaluate: (1) whether the employee engaged

in the conduct the employer alleges; (2) whether the employee’s conduct qualifies as AYERS V. CURRITUCK CTY. DEP’T OF SOC. SERVS.

Opinion of the Court

unacceptable personal conduct under the North Carolina Administrative Code; and

(3) whether that employee’s misconduct amounted to just cause for the disciplinary

action taken. See Warren v. N.C. Dep’t. of Crime Control & Pub. Safety, 221 N.C.

App. 376, 382-83, 726 S.E.2d 920, 925, disc. rev. denied, 366 N.C. 408, 735 S.E.2d 175

(2012).

¶2 However, when the Record shows an agency failed to consider a necessary

factor in determining appropriate disciplinary action to take against a career State

employee, resulting in the agency’s failure to fully exercise its discretionary review

under Wetherington v. N.C. Dep’t of Pub. Safety, the ALJ must remand to the agency

for an investigation that considers each required factor. Without the agency’s full

consideration of all factors, we cannot conduct an adequate de novo review on appeal.

See Wetherington v. N.C. Dep’t of Pub. Safety, 368 N.C. 583, 592, 780 S.E.2d 543, 548

(2015) (“Wetherington I”). Here, the agency failed to consider a required factor under

Wetherington I–resulting harm from the career State employee’s unacceptable

personal conduct–in its decision to terminate the career State employee, and the

administrative law judge failed to remand this matter to the agency for a complete

investigation and consideration of the required factor.

BACKGROUND

¶3 Respondent-Appellant Currituck County Department of Social Services (“DSS”

or “the agency”) brings its second appeal in this case. While facts from this case are AYERS V. CURRITUCK CTY. DEP’T OF SOC. SERVS.

set out in the original appeal, Ayers v. Currituck Cty. Dep’t of Soc. Servs., 267 N.C.

App. 513, 514-17, 833 S.E.2d 649, 651-53 (2019) (“Ayers I”), we include a recitation of

“the facts and procedural history relevant to the issues currently before us.” Premier,

Inc. v. Peterson, 255 N.C. App. 347, 348, 804 S.E.2d 599, 601 (2017).

A. Prior to Incident

¶4 Petitioner-Appellee Judith Ayers had been employed with DSS from 2007 until

the incident in 2017. Ayers was the supervisor for the Child Protective Services Unit

at DSS who reported directly to the DSS Director. Neither party contests that Ayers

was a career State employee.1

¶5 Ayers consistently received positive work performance reviews and had never

been disciplined as a DSS employee before the incident occurred. Until 30 June 2017,

her boss was the DSS Director, Kathy Romm, who had hired Ayers; Romm had asked

Ayers whether she wanted to take her position upon Romm’s retirement. Ayers

declined to pursue the position, and Romm hired another DSS employee, Samantha

Hurd. Both Ayers and Hurd are Caucasian women.

1 “Career State employee” is a term of art defined in N.C.G.S. § 126-1.1 as follows:

“‘[C]areer State employee’ means a State employee or an employee of a local entity who is covered by this Chapter pursuant to [N.C.G.S. §] 126-5(a)(2) who: (1) Is in a permanent position with a permanent appointment, and (2) Has been continuously employed by the State of North Carolina or a local entity as provided in [N.C.G.S. §] 126-5(a)(2) in a position subject to the North Carolina Human Resources Act for the immediate 12 preceding months.” N.C.G.S. § 126-1.1(a) (2019). At the time of the incident and subsequent termination, Ayers was a career State employee. AYERS V. CURRITUCK CTY. DEP’T OF SOC. SERVS.

¶6 Prior to Hurd’s promotion, she supervised DSS’s Foster Care Unit, and she and

Ayers had a history of disagreements and conflict in their roles. The disagreements

and conflict continued after Hurd’s promotion.

B. Incident

¶7 On 3 November 2017, Hurd asked Ayers about a racial demarcation–“NR”–

that a social worker had included on a client intake form; Hurd did not recognize the

demarcation, asked Ayers what it stood for multiple times, and Ayers responded with

a racial epithet. Ayers claimed she said “nigra rican,” while Hurd claimed Ayers said

“[n-----] rican” (“the N word”). According to testimony from Hurd and Ayers, Ayers

initially laughed about the comment, but became apologetic and embarrassed soon

afterward. After investigation, Hurd and Ayers discovered the client referred to on

the form was Caucasian.

C. Disciplinary Action

¶8 The incident occurred on Friday, 3 November 2017, and Hurd conferred with

DSS’s counsel over the following weekend. After receiving guidance, Hurd applied a

twelve-factor test, derived from a guide for North Carolina public employers

published by the University of North Carolina at Chapel Hill Institute of

Government, to Ayers’s comment and instituted disciplinary proceedings against her AYERS V. CURRITUCK CTY. DEP’T OF SOC. SERVS.

on Monday, 6 November 2017. The twelve-factor test2 included the following

considerations:

1. The nature and the seriousness of the offense and its relation to the employee’s duties, position, and responsibilities, including whether the offense was intentional or technical or inadvertent, was committed maliciously or for gain, or was frequently repeated.

2. The employee’s job level and type of employment, including supervisory or fiduciary role, contacts with the public, and prominence of the position.

3. The employee’s past disciplinary record.

4. The employee’s past work record, including length of service, performance on the job, ability to get along with fellow workers and dependability.

5. The effect of the offense upon the employee’s ability to perform at a satisfactory level and its effect upon [the] supervisor’s confidence in the employee’s ability to perform assigned duties.

6. The consistency of the penalty with those imposed[] upon other employees for the same or similar offenses.

7. The impact of the penalty upon the reputation of the agency[.]

8.

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Related

Early v. County of Durham Department of Social Services
616 S.E.2d 553 (Court of Appeals of North Carolina, 2005)
North Carolina Department of Environment & Natural Resources v. Carroll
599 S.E.2d 888 (Supreme Court of North Carolina, 2004)
Warren v. North Carolina Department of Crime Control & Public Safety
726 S.E.2d 920 (Court of Appeals of North Carolina, 2012)
Wetherington v. North Carolina Department of Public Safety
780 S.E.2d 543 (Supreme Court of North Carolina, 2015)
Mills v. N.C. Dep't of Health & Human Servs.
794 S.E.2d 566 (Court of Appeals of North Carolina, 2016)
Harris v. N.C. Dep't of Pub. Safety
798 S.E.2d 127 (Court of Appeals of North Carolina, 2017)
Brewington v. N.C. Dep't Of Pub. Safety
802 S.E.2d 115 (Court of Appeals of North Carolina, 2017)
Premier, Inc. v. Peterson
804 S.E.2d 599 (Court of Appeals of North Carolina, 2017)
Early v. County of Durham Department of Social Services
637 S.E.2d 539 (Supreme Court of North Carolina, 2006)
State v. Rodriguez
803 S.E.2d 819 (Supreme Court of North Carolina, 2017)

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