Briston v. Borough of Rankin Civil Service Commission

80 Pa. D. & C.4th 411
CourtPennsylvania Court of Common Pleas, Alleghany County
DecidedJune 12, 2006
Docketno. GD 05-4780
StatusPublished

This text of 80 Pa. D. & C.4th 411 (Briston v. Borough of Rankin Civil Service Commission) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Alleghany County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Briston v. Borough of Rankin Civil Service Commission, 80 Pa. D. & C.4th 411 (Pa. Super. Ct. 2006).

Opinion

FRIEDMAN, J,

INTRODUCTION

The captioned matter originally filed at the indicated general docket number is in the nature of a statutory appeal and was eventually transferred to that docket while keeping its original GD number. (See order dated June 6, 2005, by the Honorable R. Stanton Wettick Jr., administrative judge of this court’s civil division.) The statutory appeal was assigned to the undersigned for disposition.

FACTUAL AND PROCEDURAL HISTORY

The appellant, Darryl L. Briston, is the former police chief of intervenor, the Borough of Rankin. He claims he should be reinstated with back pay for the period of March 16, 2004 to date. This seems a simple enough question, but there are a variety of unusual facts that give rise to unusual issues.

Briston was suspended without pay for 10 days as of March 16, 2004, then again for three days as of March 30,2004, and then terminated as of April 24,2004, for a [414]*414variety of alleged offenses. He appealed the termination (but not the suspensions) and while the matter was pending before the borough’s civil service commission, he was found guilty in federal court of four felony charges apparently unrelated to the reasons for which he was terminated. 1 The guilty verdict was rendered on November 1, 2004, but he had not been sentenced prior to the commission’s instant adjudication, which is set forth in its order of January 19,2005. Since without the imposition of a sentence there is no “conviction,” the commission was not able to apply the Confidence in Law Enforcement Act, 53 P.S. §§752.1-752.5, which mandates the termination of Briston upon conviction. The commission agreed at the time that the Act’s mandate did not apply but nevertheless felt able to rule on all the pending charges and dismissed many but upheld three.

DISCUSSION

Regarding the penalty imposed by council of termination, one member voted to uphold the penalty of termination, and one voted to change the penalty from termination to a one-year suspension. (See section at the end of their adjudication, titled “Penalties imposed by borough council.”) The third member of the commission abstained.2 The court will not discuss the charges [415]*415that the commission dismissed. The commission sustained the following charges:

A. “Conduct Unbecoming an Officer, Neglect and Violation of Official Duty, ” As Described in Paragraphs 3, 7, 8 and 9 of Appendix III

Those instances involve Briston’s alleged refusal to obey orders of the mayor and the council president regarding giving the mayor access to a bulletin board so he could be sure (per advice to him by the borough’s solicitor) that a certain union petition had been posted. When the mayor was finally able, through other means, to view the bulletin board, he saw that the union petition had not been posted as required by the Pennsylvania Labor Relations Board.

B. Picking Up a Police Vehicle From a Repair Shop While Not Authorized To Do So Because He Was Then on Suspension

C.“Conduct Unbecoming of an Officer and Disobedience of Orders,” As Described in Paragraph VI of Appendix IV of the Commission s Adjudication

That conduct was described as “Failure to return computer equipment to the Borough of Rankin.” Briston had [416]*416allegedly been told repeatedly to return it and failed to do so. This was one of the post-termination charges filed on April 28, 2004, while Briston’s appeal to the commission was pending.

ISSUES ON APPEAL TO THE COURT OF COMMON PLEAS

Briston condenses his 11 issues raised on appeal to the court of common pleas into three main areas — the validity of the adjudication, the applicability of the Confidence in Law Enforcement Act, and the failure of the borough to have entered a valid termination order discharging Briston. We address these areas in reverse order below.

1. Whether the Adjudication Was Rendered by a Majority of the Quorum of the Commission

The powers and duties of the commission are set forth in 53 P.S. §46191 and in the Borough of Rankin Civil Service Rules. Section 2.3 of the Borough of Rankin Civil Service Rules states:

“Two members of the commission shall constitute a quorum and no action of the commission shall be valid unless it shall have the concurrence of at least two members.”

Here the adjudication appears ambiguous, with both commissioners sustaining three of the charges, but differing on whether the appropriate penalty was a year’s suspension without pay or termination. The question then becomes one of the power of the commission: may [417]*417it impose penalties or is it only to evaluate the charges made, with the penalty remaining one of borough council ’s discretion? If the commission has the power and the duty to impose penalties, there was clearly no “concurrence of at least two members” as to the penalty to be imposed. However, the Borough Rules show its power regarding the imposition of penalties is very limited.

Section 3.3(c) of the Borough Rules states:

“(c) In conducting the hearing, the commission’s standard of review shall be to determine whether sufficient evidence has been presented to support the statutory reason for the disciplinary action. If the commission finds that sufficient evidence has been introduced to support the charge, the commission shall not modify the penalty imposed unless it finds that the penalty imposed was arbitrary, discriminatory or an abuse of the discretion. In considering the appropriateness of the discipline, the commission shall not substitute its judgment for that of the borough council or mayor. The commission may request post-hearing briefs, and shall issue a written decision containing specific findings of fact and conclusions of law within 60 days of the receipt of the hearing transcript.”

Here, two of the three commissioners agreed that three of the charges were supported by sufficient evidence. None of them expressly or impliedly found that the penalty imposed was “arbitrary, discriminatory, or an abuse of discretion,” although one commissioner nevertheless wanted to reduce the penalty to a one-year suspension. There was, therefore, a majority vote in [418]*418support of three of the charges. The issue for the court then is to review the record to see if there was sufficient evidence presented to the commission regarding those three charges.

A review of the transcripts for the hearing of May 5, 2004 and June 16, 2004 reveals that there was ample evidence presented to support the charges. The issues of credibility were for the members of the commission. The evidence in support of the three charges was more than sufficient.

2. Whether the “Confidence in Law Enforcement” Act Applies

Briston asserts that the commission did not properly accept the borough’s supplement to the record after the hearings were over — submitting the jury verdict, but no “conviction,” along with the reference to the Confidence in Law Enforcement Act.

The borough, on the other hand, argues that now the Act is certainly relevant and does apply. The borough also points out that if the commission’s adjudication is upheld, the issue of the mandates of the Act become moot.

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Bluebook (online)
80 Pa. D. & C.4th 411, Counsel Stack Legal Research, https://law.counselstack.com/opinion/briston-v-borough-of-rankin-civil-service-commission-pactcomplallegh-2006.