Benoit v. Claremont

CourtDistrict Court, D. New Hampshire
DecidedNovember 3, 1995
DocketCV-94-268-JD
StatusPublished

This text of Benoit v. Claremont (Benoit v. Claremont) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Benoit v. Claremont, (D.N.H. 1995).

Opinion

Benoit v. Claremont CV-94-268-JD 11/03/95 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

James Benoit

v. Civil No. 94-268-JD

City of Claremont, et al.

O R D E R

The plaintiff, James Benoit, brings this action against the

defendants. City of Claremont, City of Claremont Police Depart­

ment ("Department")a Claremont Police Commission ("Commission")

and Police Chief Michael L. Prozzo, Jr., pursuant to 42 U.S.C. §§

1981 and 1983, for alleged violations of the plaintiff's right to

free speech under the First Amendment. Before the court is

Prozzo's Motion for Summary Judgment (document no. 13) on the

issue of gualified immunity.

Background1

From March 29, 1979, until February 19, 1988, James Benoit

was a police officer with the Claremont, New Hampshire, Police

1The court's recitation of the facts relevant to the instant motion are either not in dispute or have been alleged by the plaintiff. Department.2 Complaint at 5 3; Affidavit of Michael L. Prozzo,

Jr. in support of Motion for Summary Judgment ("Prozzo

Affidavit") at 55 4, 6. In the summer of 1989, Benoit again

applied for a position with the Department and was sworn in on

August 11, 1989. Prozzo Affidavit at 55 7, 9. During the

plaintiff's second tenure with the Department, he was under the

command of Prozzo, who was the police chief from November 1988,

through December 1994. Id. at 5 2. On May 10, 1994, Benoit

again resigned from the Department. Complaint at 5 24; Prozzo

Affidavit, Ex. 31.

During his tenure with the Department, Benoit received

commendations for

outstanding police performance in apprehending a burglar (November 21, 1983), for his work in combatting the influx of illegal drugs (May 8, 1980, October 30, 1990, June 1, 1991), for solving serious crimes against persons (December 8, 1989), for averting a tragedy in connection with his efforts to prevent the operator of a burning car from approaching and endangering students in a Claremont school yard (April 13, 1993), for outstanding conduct (November 29, 1983, April 16, 1984), and for disarming a dangerous person with a concealed firearm and protecting his fellow officers (March 21, 1991) .

Complaint at 5 4. In addition, the plaintiff received many

written expressions of support and appreciation from members of

21he plaintiff resigned because he was suffering from depression caused by the termination of a personal relationship. Affidavit of James Benoit ("Benoit Affidavit"), Ex. B.

2 the Claremont community for his performance as a police officer.

Id. at 5 5.

While employed as a police officer, Benoit frequently

alerted his superiors to a variety of concerns related to

personal and public safety and departmental procedure. Complaint

at 5 11. On August 23, 1993, the plaintiff requested that patrol

officers properly be vaccinated given their risk of exposure to

rabid animals. Prozzo Affidavit at 5 19. On September 21, 1993,

Benoit further requested that patrol cars no longer be used to

dispatch wild animals. Id., Ex. 11. Instead, he recommended

that city employees transport the animals or, in the alternative,

that each patrol car be equipped with sealed animal storage

containers. Id. The Department responded to the plaintiff's

concerns by issuing updated animal control procedures effective

November 4, 1993. Id., Ex. 12.

On a separate occasion, the plaintiff prevented the operator

of a burning vehicle from approaching and endangering children in

a schoolyard. Complaint at 5 14. In the course of this rescue,

Benoit was unable to communicate with other officers to warn them

of impending danger. Id. As a result, Benoit nearly collided

with another police car as he attempted to position his vehicle

in front of the burning car and bring it to a halt. Id.

3 Following this event, the plaintiff requested that the Department

review its communication policies. Id.

Shortly after expressing concern about the communication

policies, the plaintiff notified his superiors that the Depart­

ment's policies governing police response to bank alarms also

presented various dangers. Complaint at 5 15. Specifically, the

plaintiff observed that the "present rules place the responding

officer in danger of drawing fire from perpetrators without

permitting safe responding fire and place the public in danger of

being taken hostage." Id.

For several months, Prozzo was not aware of the plaintiff's

recommendations regarding "radio communication breakdown" or bank

alarm procedures because Benoit's superiors had failed to relay

these concerns to Prozzo. Prozzo Affidavit at 5 21; Complaint at

55 14-16. However, upon learning of the concerns, Prozzo

evaluated the issues raised and determined that the existing

procedures should not be modified. Prozzo Affidavit at 5 21.

In June 1993, Benoit informed the Department that dangerous

incidents involving the misuse of handguns had occurred in August

1990 in the locker room and elsewhere at police headquarters.

Complaint at 5 18; Prozzo Affidavit at 5 28. The plaintiff

alleged that certain officers had aimed handguns at, or in the

general direction of, the plaintiff and other officers. Prozzo

4 Affidavit, Ex. 20. Upon learning of these incidents, Prozzo

decided that he could not undertake an investigation because the

reported events had occurred nearly three years earlier. Id. at

5 28.

On December 26, 1993, Benoit reported a more recent incident

involving the misuse of a handgun. Prozzo Affidavit at 5 29.

Because this event was reported promptly, an internal investiga­

tion was conducted and the offending officer was disciplined by

means of a written warning. Id. In addition, Prozzo authorized

the issuance of a special order reminding officers of the

prohibition against the removal of firearms from holsters without

justification. Id.; Complaint at 5 18.

In early 1993, an officer serving on the night shift left

the Department, thereby reguiring the Department to reassign an

officer to fill the vacancy. Prozzo Affidavit at 5 27. Con­

sistent with departmental policy, the Department determined that

the least senior officer on the day shift would be transferred.

Id. The Department determined that Benoit was the least senior

officer on the day shift after having calculated the length of

his employment from 1989, the date of his re-hire. Id. at 55 22,

27. On April 20, 1993, Benoit submitted a grievance letter

contesting Prozzo's failure to include his initial nine years of

employment when determining seniority. Id. at 5 22. On May 28,

5 1993, Prozzo denied the grievance request and provided a copy of

the denial to the police union. Id. at 5 23.

On June 4, 1993, the union sent a grievance letter to the

Commission echoing Benoit's contention that the collective

bargaining agreement requires that seniority be calculated from

the date of initial hire, whether or not employment was contin­

uous. Prozzo Affidavit at 5 24 & Ex. 9 at 21. On September 22,

1993, the Commission concluded that the plaintiff's seniority had

been calculated correctly by Prozzo. Id., Ex. 17. Subsequently,

the union requested additional time to consider further appeal

options but no such action followed. Id. at 5 26.

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