Baye v. Wade

416 F. Supp. 1147, 1976 U.S. Dist. LEXIS 13940
CourtDistrict Court, M.D. Louisiana
DecidedJuly 26, 1976
DocketCiv. A. No. 71-2225
StatusPublished

This text of 416 F. Supp. 1147 (Baye v. Wade) is published on Counsel Stack Legal Research, covering District Court, M.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baye v. Wade, 416 F. Supp. 1147, 1976 U.S. Dist. LEXIS 13940 (M.D. La. 1976).

Opinion

SEAR, District Judge:

Claiborne T. Baye was a Major on full time, active duty in the Louisiana Army National Guard. In addition to his regular military duties, Baye was employed by the National Guard in a separate civilian capacity as a flight instructor. Under the provisions of the National Guard Technicians Act of 1968,1 the lowest rank eligible to qualify for such civilian employment was Warrant Officer. In November 1970 Baye decided that in order, to best fulfill his flight instruction commitments, he should surrender his commission as Major, which required that he perform extensive military duties, and assume the rank of Warrant Officer and still remain qualified for the civilian position. As a Warrant Officer, Baye would have been able to perform his military duties entirely on week-ends, leaving him free to devote his full time energies during the week to his employment as flight instructor.

Following Baye’s voluntary reduction in rank, defendant, Adjutant General David Wade discharged Baye from his civilian position as flight instructor and gave as his reason his policy that required civilian technicians serving as flight instructor also hold [1148]*1148command positions in the military arm of the Guard, a rank Baye had just resigned. On December 14, 1970, Baye received a written “Notice of Separation” from the office of the Adjutant General which notified him that his discharge became final January 15, 1971. Baye timely appealed his discharge to the appropriate military authority, who was the defendant, Adjutant General Wade who had discharged him. As one might suspect, upon review, Wade found the discharge had been proper.

Thereafter, Baye brought this suit in which he claims that he was denied due process of law. Specifically, he contends that National Guard Regulations require that he be given advance written notice of a proposed discharge and that these Regulations had not been complied with. The case progressed in the usual manner until, upon the retirement of the then sitting judge of this section of Court, it was temporarily re-allotted to another section, and in November 1975 a motion by the plaintiff for summary judgment was argued before and ruled upon by Chief Judge Heebe to whom the case was temporarily assigned.

After an initial determination that the Court had jurisdiction over the controversy despite its military nature,2 Judge Heebe examined the substance of Baye’s allegations. Firstly he held that, according to the National Guard Regulations, at the time Baye resigned from his position as a full time officer he was not entitled to notice that if he did so he would be discharged from his job as flight instructor. We note that at no time did Judge Heebe indicate that Baye was entitled to no notice at all. In fact, he clearly stated that the regulations provide for notice once “the National Guard decides what it is going to do.” In other words, the National Guard is not required to counsel its employees as to the ramifications of every possible action they may take before they take it. Once an employee has acted, however, and the Guard determines that such action is a cause for discharge, at that point the National Guard must give the notice specified by the regulations.3

Secondly, my Brother Heebe found that Baye had indeed been denied due process since his appeal from discharge had not [1149]*1149been reviewed by an impartial hearing officer, but instead had been reviewed by the officer who fired him. The Chief Judge wrote that, “It is an elementary principle of due process that ‘[N]o man shall be a judge in his own cause.’ Bonham’s Case, 8 Co. 114a, 118a, 77 E.g.Rep. 646, 652 (1610),” and noted that in a similar due process challenge, a post-termination hearing before an impartial hearing officer was made available.4 Judge Heebe ordered that such a hearing be held.

Instead of implementing Judge Heebe’s order to determine the facts that led up to the plaintiff’s discharge, the hearing officer rendered a written decision in the form of a military letter without holding the mandated hearing and erroneously concluded that the plaintiff’s firing was procedurally defective because he had not received the required advance notice.

The decision of the hearing officer was properly reversed upon review by Colonel Scholl, a member of the staff of the Adjutant General. Colonel Scholl found that the hearing officer exceeded the scope of his authority by considering the procedural aspect of the termination, and had failed to carry out Judge Heebe’s order to determine the facts. Colonel Scholl concluded that no advance notice of discharge was required in this particular case reasoning that, since the Adjutant General had appointed Baye in the first place, he could discharge him summarily.

In the meantime, the vacancy in this section of Court having been filled, the case was returned to us. Once more motions for summary judgment on behalf of both parties were argued and taken under submission by the Court.

After hearing argument and considering the facts and the law applicable to the ease, we disagree with Colonel Scholl’s reasoning and concur with Judge Heebe. At the time of his resignation of his commission as Major, the plaintiff was not entitled to notice that he would be discharged as flight instructor if he chose to resign. The plaintiff’s resignation was a voluntary act, the consequences of which he should have investigated prior to resigning. It is undisputed that the National Guard may discharge its employees for good cause and that an infinite number of actions might constitute such cause. National Guard commanders are not clairvoyant. They cannot predict the voluntary acts of their employees and so warn them in advance that they may be discharged as a result of some voluntary act or whim. However, once the decision to terminate has been made, then an employee such as the plaintiff here is entitled to notice at least thirty days before the discharge becomes effective.

The regulations set forth the particular requirements of the advance notice 5. They specify the form of the notice and what it must contain, ensuring that the employee fully understands the proposed action and the reasons for it, and giving him an opportunity to reply to the notice. Their purpose is to protect employees from “capricious, arbitrary, and unreasonable actions” by their superiors. By design, the regulations embody the basic requirements of constitutional due process: notice and an opportunity to be heard prior to a deprivation of property. They make no exception when the adverse action is taken by the appointing authority as argued by Colonel Scholl. Indeed, due process of law must be accorded in all but the most extraordinary situations.6 Needless to say, Adjutant General Wade’s initial hiring of Baye as flight instructor, does not qualify as an extraordinary circumstance which would allow the Adjutant General to discharge Baye without notice. Thus, we find that the National Guard regulations in question do require that a technician be given advance notice of [1150]*1150separation, even when the discharging authority is also the appointing authority.

However, we believe that the advance notice required by the regulations was given in this case.

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416 F. Supp. 1147, 1976 U.S. Dist. LEXIS 13940, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baye-v-wade-lamd-1976.