Bankhead v. City of Tacoma

597 P.2d 920, 23 Wash. App. 631, 1979 Wash. App. LEXIS 2508
CourtCourt of Appeals of Washington
DecidedJune 29, 1979
Docket3273-2
StatusPublished
Cited by11 cases

This text of 597 P.2d 920 (Bankhead v. City of Tacoma) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bankhead v. City of Tacoma, 597 P.2d 920, 23 Wash. App. 631, 1979 Wash. App. LEXIS 2508 (Wash. Ct. App. 1979).

Opinion

Pearson, C.J.

This appeal arises out of dismissal of a number of claims emanating from plaintiffs separation from service as a graphic arts specialist with the City of Tacoma. The claims generally involve whether plaintiff, Alan Bankhead, was properly terminated and whether he was defamed by his former supervisor. We affirm the trial court's judgment.

Plaintiff was first hired as an artist for the city in October 1971. His salary was at that time funded under a federal employment program called P.E.P. According to an undisputed affidavit, persons employed pursuant to such grants are classified as "temporary employees" of the city.

On June 10, 1974, plaintiff was given a temporary, city-funded appointment in the newly created job classification *633 of graphic arts specialist. Under the applicable rules, discussed in detail below, plaintiff retained temporary employee status while an examination for his new position was prepared and administered. Based on the examination, an eligibility list was established on February 20, 1975. Though plaintiff was ranked number 4 on that list, he continued to be employed in the graphic arts specialist job pending appointment of a permanent employee.

On June 9, 1975, plaintiff was permanently appointed to the graphic arts specialist position by the city clerk, the appropriate appointing officer. Under the applicable rules, he was required to serve a 9-month probationary period before acquiring full civil service status. He was subject to termination during his probationary period without all of the procedural rights associated with termination of a non-probationary permanent employee. 1

*634 During his probationary period, plaintiff took 8 days of sick leave which, according to the city's contention, extended his probation by 8 days. Five days before the end of his probationary period, as extended, plaintiff was terminated by the city clerk.

Plaintiff requested, and was granted, an administrative review of the termination by an administrative board. He was not afforded a full hearing before the Tacoma Civil Service Commission, on the basis that he was a probationary employee when he was terminated. During the course of this review, the city clerk twice supplied written rationales for his action. After the dismissal was upheld, the clerk, on three occasions, communicated that fact to prospective employers of plaintiff. In these various communications, plaintiff alleges he was defamed.

After his termination, plaintiff brought suit against the city, the city clerk, and a fellow employee. On motion by the defendants, summary judgment was granted on all of plaintiff's claims except for one involving an alleged assault by the fellow employee. That claim has been set down for trial and is not part of this appeal.

In order to decide the issues raised on appeal, we must first define the scope of judicial review of the challenged actions. Because of the nature of the alleged errors, considering the propriety of judicial review requires us to consider both the question of plaintiff's standing and whether or not the action of the city involved a so-called "fundamental right." See Wilson v. Nord, 23 Wn. App. 366, 597 P.2d 914 (1979).

*635 In the Superior Court and in this court, all parties have agreed that review of the case is proceeding under the inherent power of the court, granted by article 4, sections 1 and 6 of the state constitution, to review administrative actions to determine whether they are arbitrary and capricious, or contrary to law. State ex rel. Hood v. State Personnel Bd., 82 Wn.2d 396, 511 P.2d 52 (1973). The concept of violation of a fundamental right has long been associated with review of administrative actions under the court's inherent power. But as we explained in Wilson u. Nord, supra,- the fundamental right concept means a petitioner has a right to enforce the requirement that an agency abide by the constitution, statutes, and regulations in the exercise of its discretion regarding him.

Initially, a party challenging an administrative action must possess standing, just as any litigant must. Standing has been defined as a presently existing, substantial interest in the subject matter of the suit which will be affected by the relief granted. State ex rel. Hays v. Wilson, 17 Wn.2d 670, 137 P.2d 105 (1943). The presence of some violation of law is not sufficient if the party challenging an action lacks standing to challenge the violation.

With these concepts in mind, we turn to the first set of issues raised by plaintiff. The basic contention raised is that plaintiff was not properly terminated because he had completed his probationary period prior to his termination. The argument is that the appointment must have occurred, by law, prior to the date shown by the record.

Plaintiff's first contention is that the city or its agents acted arbitrarily and capriciously in not appointing him in February, when the eligibility list was established, rather than in June, when he was actually appointed. In support of this contention, plaintiff cites section 6.14(h) of the Tacoma City Charter 2 and section 1.24.210 of the Tacoma *636 Municipal Code 3 for the proposition that his temporary position ceased to exist when the eligibility list became available in February 1975. From this, plaintiff argues that since he was not a temporary employee he must have been a permanent one. From this conclusion, plaintiff derives the further conclusion that the city acted arbitrarily in not appointing him permanently in February 1975.

We are unable to agree with these contentions. While it is true plaintiff alleges that the City violated its own rules, these violations, even if they occurred, do not entitle plaintiff to relief unless he has standing to challenge them. The rules in question are designed to promote efficiency in appointments by city agencies and to prevent circumvention of the civil service rules by the use of temporary appointments. They are not designed to allow an employee to choose his appointment date. It is the employer, not the employee, who makes the appointment and determines its effective date. See Ross v. Department of Social & Health Servs., 23 Wn. App. 265, 594 P.2d 1386 (1979).

Had plaintiff been terminated when the eligibility list was first available and not reappointed until 6 months later, the situation would obviously be different. Likewise, had plaintiff been a person not employed by the city, but seeking such employment, his situation would have been different. He would then have had a direct economic stake in assuring that the appointment was made expeditiously.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Compton v. O'Bryan
S.D. West Virginia, 2018
Dunn v. HYRA
676 F. Supp. 2d 1172 (W.D. Washington, 2009)
Miron v. University of New Haven Police Department
931 A.2d 847 (Supreme Court of Connecticut, 2007)
Stimus v. Hagstrom
944 P.2d 1076 (Court of Appeals of Washington, 1997)
Rice v. Janovich
742 P.2d 1230 (Washington Supreme Court, 1987)
Pacific Wire Works, Inc. v. Department of Labor & Industries
742 P.2d 168 (Court of Appeals of Washington, 1987)
Criss v. Criss
356 S.E.2d 620 (West Virginia Supreme Court, 1987)
Georgia Power Co. v. Campaign for a Prosperous Georgia
336 S.E.2d 790 (Supreme Court of Georgia, 1985)
Columbia Mortgage Co. v. Hsieh
708 P.2d 1226 (Court of Appeals of Washington, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
597 P.2d 920, 23 Wash. App. 631, 1979 Wash. App. LEXIS 2508, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bankhead-v-city-of-tacoma-washctapp-1979.