City of Little Rock and the Little Rock Police Departmenb v. Charles Starks

2025 Ark. App. 1, 705 S.W.3d 1
CourtCourt of Appeals of Arkansas
DecidedJanuary 8, 2025
StatusPublished

This text of 2025 Ark. App. 1 (City of Little Rock and the Little Rock Police Departmenb v. Charles Starks) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Little Rock and the Little Rock Police Departmenb v. Charles Starks, 2025 Ark. App. 1, 705 S.W.3d 1 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 1 ARKANSAS COURT OF APPEALS DIVISION II NO. CV-23-226

Opinion Delivered January 8, 2025 CITY OF LITTLE ROCK AND THE LITTLE ROCK POLICE APPEAL FROM THE PULASKI DEPARTMENT COUNTY CIRCUIT COURT, SIXTH APPELLANTS DIVISION [NO. 60CV-19-7042] V. HONORABLE TIMOTHY DAVIS FOX, CHARLES STARKS JUDGE APPELLEE AFFIRMED

STEPHANIE POTTER BARRETT, Judge

This is the second appeal by the City of Little Rock and the Little Rock Police

Department (collectively, “Little Rock”) regarding the termination of Charles Starks, a Little

Rock police officer, after he fatally shot Bradley Blackshire in the line of duty. The Little

Rock Civil Service Commission (“Commission”) terminated Starks’s employment because it

determined that Starks had violated General Order 303.II.E.2 (“General Order”), which

provides, “Officers will not voluntarily place themselves in a position in front of an

oncoming vehicle where Deadly Force is the probable outcome. When confronted by an

oncoming vehicle, officers will move out of its path, if possible, rather than fire at the

vehicle.” Little Rock Police Department General Order No. 303.II.E.2 (2017). Starks

appealed his termination to the Pulaski County Circuit Court, which affirmed the Commission’s finding that he had violated the General Order but reversed the

Commission’s termination decision, instead reducing Starks’s salary and ordering a thirty-

day suspension. In its decision, the circuit court divided Starks’s actions during the

encounter into nonemergency and emergency portions, finding Starks had violated the

General Order during the nonemergency portion but not during the emergency portion. In

making its decision, the circuit court analyzed Starks’s actions using a reasonableness

standard.

Little Rock appealed the circuit court’s decision to this court, arguing on direct appeal

that the termination of Starks’s employment should stand; Starks cross-appealed, asserting

that he had not violated the General Order, and therefore, no punishment was warranted.

In Little Rock Police Department v. Starks, 2021 Ark. App. 323 (Starks I), this court reversed

and remanded the case to the circuit court, holding that the case was

simply a question of whether General Order 303.II.E.2 was violated, and that question must be analyzed under the voluntariness of the act, not a reasonableness standard as used by the circuit court. Therefore, there is no need to divide the situation into emergency or nonemergency situations nor to determine whether the actions were reasonable for an officer with similar training and experience. Simply posed, did Starks voluntarily violate General Order 303.II.E.2 by placing himself in a position in front of an oncoming vehicle where deadly force was the probable outcome?

2021 Ark. App. 323, at 5.

In an order filed on January 19, 2023, the circuit court stated that it had conducted

a de novo review of the record, it specifically found that Starks did not voluntarily place

himself in a position in front of an oncoming vehicle in violation of the General Order, and

2 it reversed Starks’s termination, reinstating him effective May 6, 2019, and ordering that

Starks be paid all salary as well as payment of or reimbursement for all benefits due him from

May 6, 2019, through the implementation of the order.

Little Rock appeals, arguing that (1) the circuit court’s determination that Starks did

not violate the General Order is against the preponderance of the evidence and clearly

erroneous; and (2) its decision to overturn Starks’s termination and order reinstatement was

also against the preponderance of the evidence and clearly erroneous because Starks violated

the General Order, and the death of a civilian resulted because of that violation. We affirm

the circuit court’s decision that Starks did not violate the General Order.

I. Facts

The facts of this case were set forth in Starks I:

Charles Starks is a certified law enforcement officer who began working as a patrol officer in the Little Rock Police Department in approximately August 2013. On Friday, February 22, 2019, Starks was working patrol when he received notification of a stolen vehicle in the area of 12th Street and Rodney Parham, responded to the call, and traveled to that general area. He was subsequently notified that the stolen vehicle had made a left turn into a parking lot near 7305 Kanis Road and that the operator of the stolen motor vehicle had backed the car into a parking space and was stationary. Starks was informed that Officer Zebulum Tyler was en route to assist him and was “gonna be a minute” before arrival. Starks specifically parked his patrol car in front of the stolen vehicle, partially blocking the vehicle in such a manner that the operator of the stolen vehicle still had room to flee.

The video footage of the incident shows that at approximately 1109 hours, Officer Starks exited his patrol car, passed in front of the stolen vehicle, and approached the driver’s side door with his weapon drawn. Starks ordered the driver to show his hands, roll the window down, and exit the vehicle. The driver did not comply with Officer Starks’s commands. Testimony by Officer Starks indicated that he saw the suspect reach over and put the car into gear. Officer Starks then saw the suspect reach down near his leg to an area that Officer Starks could not see. Officer

3 Starks believed that the driver, Bradley Blackshire, was reaching for a gun. Officer Starks continued to give Blackshire commands as he walked backward and positioned himself near the front driver’s door panel. Blackshire turned to avoid hitting the patrol car and attempted to flee. In this process, Blackshire hit the officer with the car, injuring his knee and causing him to stumble backward. Starks fired three to four rounds at the driver. The stolen vehicle paused briefly and then began moving again. Starks testified that he attempted to seek cover from his car, and as he moved from his position toward his car, he was directly in front of the stolen vehicle. When the stolen vehicle began moving forward again, Starks ended up on the hood of the stolen vehicle, and from there, he fired an additional ten to eleven rounds at Blackshire. Blackshire died as a result of the gunshot wounds sustained during the incident.

2021 Ark. App. 323, at 1–2.

II. Standard of Review

A city or employee has the right to appeal any decision of the Civil Service

Commission to the circuit court within whose jurisdiction the commission is situated. Ark.

Code Ann. § 14-51-308(e)(1)(A) (Supp. 2019). The circuit court reviews decisions of the

Civil Service Commission de novo and has jurisdiction to modify the punishment fixed by

the commission, even if the circuit court agrees that the officer violated department rules

and regulations, and even if the evidence it relies on in modifying the punishment was not

presented to the Commission. Little Rock Police Dep’t v. Phillips, 2017 Ark. App. 410, 526

S.W.3d 872. The circuit court does not merely review the Commission’s decision for error

but instead conducts a de novo hearing on the record made before the Commission and any

additional competent testimony required by either party. Sears v. City of Hot Springs, 2020

Ark. App. 247, 601 S.W.3d 426. Our supreme court has held that the effect of a de novo

appeal from the Commission to the circuit court is “to reopen the entire matter for

4 consideration by the circuit court, as if a proceeding had been originally brought in that

forum.

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Related

City of Little Rock v. Hudson
236 S.W.3d 509 (Supreme Court of Arkansas, 2006)
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2024 Ark. App. 466 (Court of Appeals of Arkansas, 2024)
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Little Rock Police Department and the City of Little Rock v. Charles Starks
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