City of Shreveport v. Shreveport Municipal Fire and Police Civil Service Board and Officer Orlando Peyton

CourtLouisiana Court of Appeal
DecidedMay 26, 2021
Docket53,954-CA
StatusPublished

This text of City of Shreveport v. Shreveport Municipal Fire and Police Civil Service Board and Officer Orlando Peyton (City of Shreveport v. Shreveport Municipal Fire and Police Civil Service Board and Officer Orlando Peyton) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Shreveport v. Shreveport Municipal Fire and Police Civil Service Board and Officer Orlando Peyton, (La. Ct. App. 2021).

Opinion

Judgment rendered May 26, 2021. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 53,954-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

CITY OF SHREVEPORT Plaintiff-Appellant

versus

SHREVEPORT MUNICIPAL FIRE Defendants-Appellees AND POLICE CIVIL SERVICE BOARD AND OFFICER ORLANDO PEYTON

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 618,582

Honorable Ramon Lafitte, Judge

CARMOUCHE, BOKENFOHR, Counsel for Appellant BUCKLE & DAY, PLLC By: Nichole M. Buckle

BILLY R. CASEY Counsel for Appellee, Shreveport Municipal Fire and Police Civil Service Board

BREEDLOVE LAW FIRM Counsel for Appellee, By: Pamela Breedlove Officer Orlando Peyton

Before GARRETT, STEPHENS, and THOMPSON, JJ. THOMPSON, J.

A police officer, asserting he had not been afforded his due process

rights for a timely hearing, appealed to the civil service board to have

removed from his personnel files a sustained complaint against him by his

superior officers regarding claimed sick leave. The police officer asserted

that the sustained complaint was an absolute nullity. The civil service board,

without an evidentiary hearing to determine if the sustained complaint

amounted to a disciplinary or corrective action against the officer, ordered

the sustained complaint removed from his file. The municipality was

allowed to present proffered testimony and evidence on the record. The

district court held that the sustained complaint was an adverse action, which

amounts to corrective or disciplinary in nature, and affirmed the decision by

the civil service board and ordered the sustained complaint removed from

the officer’s records. The district court also held the civil service board

acted in good faith and was not arbitrary or capricious in reaching its

decision. The municipality appealed the district court’s judgment. For the

reasons set forth more fully herein, we affirm the district court’s judgment.

FACTS

In December of 2018, a complaint was filed with the Shreveport

Police Department Internal Affairs Bureau (“IAB”) about a potential

violation of a general order by Officer Orlando Peyton (“Officer Peyton”),

for his alleged failure to remain in his residence during a period for which he

was claiming sick leave from work. IAB began an investigation, which

commenced on February 2, 2019. Louisiana law requires that when a

formal, written complaint is made against any police officer, the investigation into the complaint, including notice to the officer that the

charges against him have been sustained and a pre-disciplinary hearing has

been scheduled, must be completed within sixty days, unless the parties

enter into a mutually agreed upon extension.1 Here, the parties agreed to a

15-day extension, leaving February 17, 2019, as the deadline for the

completion of the investigation, which includes notice of the pre-disciplinary

hearing.

The City of Shreveport (“City”) alleges that Lieutenant John Eatman

concluded that there was a violation of policy by Officer Peyton and

submitted his investigative report to the chief of police for his review. The

complaint was sustained by Chief Ben Raymond on February 12, 2019, with

1 La. R.S. 40:2531(B)(7) states:

When a formal, written complaint is made against any police employee or law enforcement officer, the superintendent of state police or the chief of police or his authorized representative shall initiate an investigation within fourteen days of the date the complaint is made. Except as otherwise provided in this Paragraph, each investigation of a police employee or law enforcement officer which is conducted under the provisions of this Chapter shall be completed within sixty days. However, in each municipality which is subject to a Municipal Fire and Police Civil Service law, the municipal police department may petition the Municipal Fire and Police Civil Service Board for an extension of the time within which to complete the investigation. The board shall set the matter for hearing and shall provide notice of the hearing to the police employee or law enforcement officer who is under investigation. The police employee or law enforcement officer who is under investigation shall have the right to attend the hearing and to present evidence and arguments against the extension. If the board finds that the municipal police department has shown good cause for the granting of an extension of time within which to complete the investigation, the board shall grant an extension of up to sixty days. Nothing contained in this Paragraph shall be construed to prohibit the police employee or law enforcement officer under investigation and the appointing authority from entering into a written agreement extending the investigation for up to an additional sixty days. The investigation shall be considered complete upon notice to the police employee or law enforcement officer under investigation of a pre- disciplinary hearing or a determination of an unfounded or unsustained complaint. Nothing in this Paragraph shall limit any investigation of alleged criminal activity.

2 instructions to schedule a pre-disciplinary hearing. However, notice was not

provided to Officer Peyton of the sustained complaint and scheduled pre-

disciplinary hearing before the February 17, 2019 deadline, and the hearing

never occurred. As a result, Officer Peyton was not afforded the opportunity

to refute the complaint lodged against him.

A document entitled “Shreveport Police Department Comments Page”

was placed in Officer Peyton’s IAB file (the “sustained complaint”). The

sustained complaint includes the IAB Control Number, has a circle around

the word “concur” that is signed by the deputy chief, and includes a box that

states: “The Appointing Authority comments on which alleged violations, if

any, to hold a PDC. Sustained- violation of 301.06. Hold PDH. Do not hold

PDH-violation of 60 days and extension.”2 This portion of the document is

signed by the police chief. The sustained complaint was placed in Officer

Peyton’s IAB file but not in his human resources file. The IAB records and

the human resources records are kept at different physical locations, but all

are accessible by computer. The contents of both records can be accessed by

current and potential employers in making promotion and employment

decisions.

2 The following are the possible administrative findings that can be made during an IAB investigation: 1) Sustained: there was a violation of written police, procedure, rule, regulation or law and the findings are validated through direct evidence and/or testimony; 2) Not Sustained: It cannot be determined whether there was a violation of written policy, procedure, rule, regulation or law; 3) Exonerated: the action complained of did occur but was lawful, proper, and within departmental guidelines; 4) Unfounded: There was no violation of written policy, procedure, rule, regulation or law; 5) Policy Failure: The allegations in the complaint are true but the employee’s actions were consistent with department policy, and the policy will be examined for revision; 6) False Complaint: The allegations are false; and 7) Exceptional Clearance: If the complaint cannot be classified into one of the above categories, the chief of police or designee has discretion to classify the complaint as an “exceptional clearance” and must state the reasons for such classification in writing.

3 PROCEDURAL HISTORY

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Moore v. Ware
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Bluebook (online)
City of Shreveport v. Shreveport Municipal Fire and Police Civil Service Board and Officer Orlando Peyton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-shreveport-v-shreveport-municipal-fire-and-police-civil-service-lactapp-2021.