Culpepper v. N.C. Off. of Admin. Hearings

CourtCourt of Appeals of North Carolina
DecidedJanuary 2, 2024
Docket23-236
StatusPublished

This text of Culpepper v. N.C. Off. of Admin. Hearings (Culpepper v. N.C. Off. of Admin. Hearings) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Culpepper v. N.C. Off. of Admin. Hearings, (N.C. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA23-236

Filed 2 January 2024

Office of Administrative Hearings, No. 22 OSP 00401

WILLIAM T. CULPEPPER, III, Petitioner,

v.

N.C. OFFICE OF ADMINISTRATIVE HEARINGS, Respondent.

Appeal by Petitioner from a final decision entered 2 December 2022 by

Administrative Law Judge Beecher R. Gray in the Office of Administrative Hearings.

Heard in the Court of Appeals 20 September 2023.

Hornthal, Riley, Ellis & Maland, L.L.P., by John D. Leidy, for petitioner- appellant.

Attorney General Joshua H. Stein, by Special Deputy Attorney General Joseph Finarelli, for respondent-appellee.

WOOD, Judge.

William Culpepper (“Petitioner”) alleges the Office of Administrative Hearings

(“OAH” or “Respondent”) engaged in political affiliation discrimination by

designating the position of General Counsel at OAH as exempt from the provisions of

the Human Resources Act, a position he held from 1 January 2015 to 30 June 2022.

We hold the trial court did not err by granting summary judgment in Respondent’s

favor because Petitioner failed to carry his burden of establishing a prima facie case

of political affiliation discrimination. CULPEPPER V. N.C. OFFICE OF ADMINISTRATIVE HEARINGS

Opinion of the Court

I. Factual and Procedural History

Petitioner is a member of the North Carolina State Bar and practiced law in

Edenton, North Carolina from 6 September 1973 until 1 January 2006. Petitioner

served as an elected Democrat member of the North Carolina House of

Representatives from 5 May 1993 until 1 January 2006 and alleges his reputation as

a prominent Democrat was widely known and reported in the news during his time

in office.

In October 2014, Petitioner applied for the position of General Counsel with

the OAH. The Job Class Title for this position was “Attorney II.” The description of

work provided in the job posting for the position stated the hired employee:

“performs a full range of legal services in matters affecting the legal responsibilities of OAH[,] . . . provides the delivery of legal services involving legal advice, opinions, research, writing, adjudications, consultations, mediations, and judicial administration[,] . . . act[s] as the agency rule coordinator[,] . . . [and] prepares opinions on North Carolina law for the three divisions [Civil Rights, Rules, and Hearings].

Petitioner was appointed to the position effective 1 January 2015.

On 1 July 2021, Chief Justice Paul Newby of our Supreme Court appointed

Donald van der Vaart (“Director van der Vaart”) as the Director and Chief

Administrative Law Judge of OAH. Petitioner alleges Director van der Vaart is a

registered Republican. Petitioner further alleges that, according to OAH’s Senior

Administrative Law Judge Fred Morrison (“Judge Morrison”), shortly after Director

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van der Vaart assumed his position at OAH, Director van der Vaart asked Judge

Morrison why Petitioner was at OAH.1 Judge Morrison allegedly replied to Director

van der Vaart that he and Petitioner had a long association over the years, Petitioner

was no longer involved in politics, was loyal to OAH, and he would be loyal to Director

van der Vaart.

As part of the Current Operations Appropriations Act of 2021 (S.L. 2021-180,

S.B. 105) enacted on 18 November 2021, the General Assembly included a provision

(the “Special Provision”) allowing the Chief Administrative Law Judge to designate

five OAH employees as exempt from the Human Resources Act. The Special

Provision reads:

The number of administrative law judges and employees of the Office of Administrative Hearings shall be established by the General Assembly. The Chief Administrative Law Judge and five employees of the Office of Administrative Hearings as designated by the Chief Administrative Law Judge are exempt from provisions of the North Carolina Human Resources Act as provided by [N.C. Gen. Stat. §] 126-5(c1)(27). All other employees of the Office of Administrative Hearings are subject to the North Carolina Human Resources Act.

Current Operations Appropriations Act of 2021, S.L. 2021-180 (S.B. 105).

Petitioner alleges Judge Morrison told him about a purported meeting between

Director van der Vaart and Kenan Drum (“Drum”) at the Legislative Building prior

1 Director van der Vaart states in his affidavit he was aware Petitioner had been appointed to serve

on the North Carolina Utilities Commission by a former Democrat Governor.

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to the Special Provision becoming public on 15 November 2021. Drum was the Policy

Advisor for General Government Appropriations to the Senate President Pro

Tempore. Petitioner alleges that, according to Judge Morrison, the meeting was

arranged by Ashley Berger Snyder (“Ms. Snyder”), Senator Berger’s daughter.

Petitioner alleges the appropriations budget for OAH is formulated by the General

Government Appropriations Subcommittee of the General Assembly’s House and

Senate. Petitioner further alleges Judge Morrison was told by Director van der Vaart

that Drum had referred to Judge Morrison as an “old time Democrat.”

After the Special Provision became public, “much talk and concern” arose

among OAH personnel, particularly among the Administrative Law Judges (“ALJ”).

According to Judge Morrison, when Director van der Vaart heard about these

concerns, he sought to allay the ALJs’ fears by proclaiming that the Special Provision

was not meant for them. Judge Morrison allegedly told Director van der Vaart one

person felt the Special Provision was directed at him. Judge Morrison told Petitioner

that he felt that Director van der Vaart was referring to Petitioner, but neither

specifically stated Petitioner’s name. Director van der Vaart replied to Judge

Morrison, “that might be right,” or words to that effect. The Petitioner discussed with

Judge Morrison his fears regarding the Special Provision adversely affecting his

employment.

By letter dated 4 January 2022, Director van der Vaart notified Petitioner he

was designating the position of General Counsel as exempt from the State Human

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Resources Act, pursuant to the authority in the Special Provision. The letter

informed Petitioner of the right to appeal the designation pursuant to N.C. Gen. Stat.

§ 126-5(h) and provided information on commencing a contested case under N.C. Gen.

Stat. § 150B-23. On 2 February 2022, Petitioner filed a Petition for a Contested Case

Hearing in which he alleged Respondent: (1) designated his position as an exempt

managerial position based on Respondent's discrimination against Petitioner due to

his political affiliation in violation of N.C. Gen. Stat. § 126-34.02(b) (2022); (2)

improperly designated his position as an exempt managerial position as defined by

N.C. Gen. Stat. § 126-5(b)(2) (the “Designation Claim”); and (3) violated Petitioner’s

state and federal constitutional rights by changing the position’s designation.

On 10 February 2022, Respondent filed its letter to Petitioner notifying him of

his position’s designation change. This letter documented the agency action from

which Petitioner filed his petition for a contested case hearing. On 11 February 2022,

Respondent filed a Partial Motion to Dismiss pursuant to N.C. R. Civ. P.

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