Dougherty v. Muhlenberg Township Civil Service Commission

46 Pa. D. & C.4th 5, 2000 Pa. Dist. & Cnty. Dec. LEXIS 268
CourtPennsylvania Court of Common Pleas, Berks County
DecidedJune 13, 2000
Docketno. 99-6424
StatusPublished

This text of 46 Pa. D. & C.4th 5 (Dougherty v. Muhlenberg Township Civil Service Commission) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Berks County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dougherty v. Muhlenberg Township Civil Service Commission, 46 Pa. D. & C.4th 5, 2000 Pa. Dist. & Cnty. Dec. LEXIS 268 (Pa. Super. Ct. 2000).

Opinion

STALLONE, J.,

The petitioner, Corporal Thomas R Dougherty, has been employed by the Muhlenberg Township Police Department for the past 21 years.1 On October 3,1998, Sergeant Todd A. Graeff of the Muhlenberg Township Police Department filed a written complaint against Corporal Dougherty with Kirk Trate, who at that time was deputy chief of the Muhlenberg Township Police Department, which contained four separate allegations of misconduct: (1) discourtesy; (2) insubordination; (3) conduct unbecoming an officer; and (4) noncompliance with departmental orders. These allegations arose out of incidents which had allegedly occurred on August 13,1998 and Septem[7]*7ber 30,1998.2 This complaint, as we now know, sets forth not only the specific allegations of misconduct against Corporal Dougherty, but also the evidence which allegedly supported those allegations.

After receiving the complaint, Deputy Chief Trate ordered Sergeant Herbert B. Roth of the Muhlenberg Township Police Department to conduct an internal investigation of the matter. Upon completing his investigation, Sergeant Roth prepared and signed a one-half page document which is captioned as a “Notification of complaint,” 3 and summarizes the four allegations of misconduct against Corporal Dougherty but does not cite any of the evidence set forth in Sergeant Graeff’s October 3, 1998 complaint. The “Notification of complaint” reads as follows:

“Corporal Thomas P. Dougherty... Muhlenberg Twp. P.D.
“You are hereby notified that a complaint has been received concerning an incident in which you are alleged to have been involved. The details of the complaint are as follows:
“that you were unwilling to obey lawful departmental orders, policies and directives. This occurred when you were asked to conduct traffic checks and to comply with directives regarding foot patrols, security checks and patrol checks. Furthermore you were insubordinate in your contact and interaction with Sergeant Todd A. Graeff who was supervising your work shift. You also violated [8]*8the courtesy provisions of the department Rules of Conduct in that you used insulting, profane and demeaning language in your interaction with Sergeant Graeff.”

At a meeting held on October 21,1998, Sergeant Roth and Robert Flanagan, chief of police of the Muhlenberg Township Police Department, served the “Notification of complaint” on Corporal Dougherty and asked him to sign it. Corporal Dougherty refused to do so because Chief Flanagan did not grant his request for a copy of Sergeant Graeff’s October 3, 1998 complaint, citing an unwritten policy of the Muhlenberg Township Police Department not to provide a copy of a written complaint to the subject of an ongoing investigation when the subject has not given either a statement or other response to the subject matter of a complaint. Corporal Dougherty made the same request of Sergeant Roth on December 8, 1998, but his request was again refused for the same reason.

On January 12, 1999, Chief Flanagan provided Corporal Dougherty with an undated and unsigned copy of a two-page document captioned “Internal investigation,” 4 and asked Corporal Dougherty to respond to it: However, this document merely contained a series of general statements describing Corporal Dougherty’s conduct subsequent to the filing of Sergeant Graeff’s October 3, 1998 complaint and did not refer either to Corporal Dougherty by name or to any evidence allegedly supporting, the misconduct charges against him. Interestingly, there is also a two-page document in the record captioned as a [9]*9“General investigation report”5 dated December 8,1998, which contains a partial summary of the evidence allegedly supporting the allegations of misconduct as contained in the complaint against Corporal Dougherty but which, like the October 3, 1998 written complaint, was never provided to Corporal Dougherty.

On January 13, 1999, Corporal Dougherty informed Chief Flanagan in writing that he could not respond in writing or otherwise to the charges of misconduct because he had not yet been given a copy of Sergeant Graeff’s October 3, 1998 complaint, and that none of the documentation which he had received up to that time stated what he allegedly said and when he allegedly said it.6 Immediately thereafter, Corporal Dougherty met with Deputy Chief Trate for a “question and answer” session about the charges, after which Deputy Chief Trate reduced his questions and Corporal Dougherty’s answers to them to a writing.7 In addition, that same day, notwithstanding his requests and the fact that he still had not received a copy of Sergeant Graeff’s written complaint, Corporal Dougherty submitted a three-page written response to the “Internal investigation” report provided to him the preceding day by Chief Flanagan.8

On January 15, 1999, Corporal Dougherty appeared for a “pre-disciplinary hearing” before Chief Flanagan. [10]*10The record indicates that the only thing that occurred at this time was that Chief Flanagan gave Corporal Dougherty the opportunity to: “verbally communicate to this officer or submit a to/from letter to this writer [Chief Flanagan] setting forth any facts that would benefit him with the final decision and determine any disciplinary action taken .9

Corporal Dougherty stated that he had nothing to add to what was already communicated to Chief Flanagan.10

On January 20,1999, Chief Flanagan issued a written decision11 suspending Corporal Dougherty without pay effective immediately until January 23, 1999.12 Corporal Dougherty requested a hearing before the Muhlenberg Township Civil Service Commission,13 which thereafter affirmed the suspension by decision dated June 9,1999. Corporal Dougherty has now filed a petition for review with this court of common pleas, in which he contends that: (1) the civil service commission erred as a matter of law in concluding that, as a tenured public employee, he was accorded sufficient procedural due process rights [11]*11before being suspended;14 and (2) the civil service commission’s findings of fact are not supported by substantial evidence.

In Pennsylvania, the standard of review of a local agency decision is well settled. Where, as here, a complete record was developed before the local agency, the reviewing court must affirm the decision unless it is determined that an error of law was committed or that material findings of fact are not supported by substantial evidence. Public Advocate v. Philadelphia Gas Commission, 544 Pa. 129, 137-38, 674 A.2d 1056, 1060 (1996). For the reasons which follow, we agree with Corporal Dougherty’s argument relative to the procedural due process issue and, therefore, we need not reach his second argument challenging the civil service commission’s findings of fact.

In the action at bar, the. township does not dispute the fact that, under applicable law, Corporal Dougherty was entitled to some minimum amount of due process prior to being suspended. See brief of Muhlenberg Township at p. 3.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cleveland Board of Education v. Loudermill
470 U.S. 532 (Supreme Court, 1985)
Public Advocate v. Philadelphia Gas Commission
674 A.2d 1056 (Supreme Court of Pennsylvania, 1996)
Cerceo v. Darby
281 A.2d 251 (Commonwealth Court of Pennsylvania, 1971)

Cite This Page — Counsel Stack

Bluebook (online)
46 Pa. D. & C.4th 5, 2000 Pa. Dist. & Cnty. Dec. LEXIS 268, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dougherty-v-muhlenberg-township-civil-service-commission-pactcomplberks-2000.