Elizabeth Smith v. City of St. Louis

CourtMissouri Court of Appeals
DecidedSeptember 14, 2021
DocketED109423
StatusPublished

This text of Elizabeth Smith v. City of St. Louis (Elizabeth Smith v. City of St. Louis) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elizabeth Smith v. City of St. Louis, (Mo. Ct. App. 2021).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION THREE

) ELIZABETH SMITH, ) No. ED109423 ) Appellant, ) Appeal from the Circuit Court ) of the City of St. Louis vs. ) Case No. 1922-CC11551 ) CITY OF ST. LOUIS, ) Honorable Joan L. Moriarty ) Respondent. ) Filed: September 14, 2021

Elizabeth Smith appeals the judgment entered by the Circuit Court of the City of St.

Louis affirming the decision of the St. Louis City Civil Service Commission to suspend her from

her employment for 15 days. Because the Commission failed to adhere to the procedural

safeguards contained in its written submission process, thus violating Smith’s due process rights,

we reverse the Commission’s decision.

Factual and Procedural Background

The City employed Smith as a paramedic in the St. Louis Fire Department. In July 2018,

Smith submitted Family/Medical Leave forms to the City’s Fire Division Medical Officer. Upon

seeking clarification about the content of Smith’s forms, the Medical Officer discovered that the

doctor who purportedly signed the forms on July 30, 2018 had left his local medical practice and

had not worked in Missouri for five months. The St. Louis Fire Department Disciplinary Review Board conducted a pre-disciplinary

review for Smith. During the review, Fire Chief Dennis Jenkerson advised Smith of the charges

against her, gave her an explanation of the evidence, and gave her an opportunity to present any

disputed facts or mitigating circumstances. Smith maintained that the physician’s signature on

her medical leave forms resulted from a clerical error in the physician’s office, and that she did

not notice the error before submitting the forms. The Disciplinary Review Board found that

Smith’s actions violated the Division of Fire and Fire Prevention rules and regulations that: (1)

prohibit the making of untruthful and inaccurate reports and the making of misleading statements

with intent to deceive; (2) require prescribed forms be completely and accurately filled out; and

(3) prohibit the filing of false reports. The Disciplinary Review Board suspended Smith for 96

hours. The City’s Personnel Department informed the Disciplinary Review Board that Smith’s

suspension must be expressed in terms of calendar days, not hours, and that the hearing must be

conducted again. Therefore, Chief Jenkerson held the hearing again, reviewed the same

information, and imposed a suspension of 15 calendar days encompassing eight 12-hour shifts

within those 15 days.

Smith appealed to the City’s Civil Service Commission. The Commission sent Smith a

letter dated December 11, 2018 describing the appeal process, which stated in pertinent part:

If you wish to proceed with your appeal before the Civil Service Commission, please indicate with a check mark in one of the boxes below which type of hearing you are requesting and return the form within ten (10) calendar days to the Civil Service Commission if you wish to proceed with your appeal. The Civil Service Commission recommends and encourages the use of the written submission process. It believes it is an efficient and effective method to get issues before the Commission. Failure to respond, marking more than one box or failing to mark any box shall result in you waiving your right to an evidentiary hearing before a hearing officer and your appeal will be handled through the written submission process.

2 (Italicized emphases added). At the bottom of the letter were three boxes identifying the options

available to Smith, and the letter instructed her to choose one: (1) written submission; (2)

evidentiary hearing before a hearing officer; or (3) declining to proceed with the appeal. Smith

marked the box for the written submission option, and signed, dated, and printed her address on

the form. Nowhere did the letter state that Smith waived her due process rights if she chose the

recommended written submission process “type of hearing.”

Following Smith’s election to proceed via the written submission process, the

Commission sent Smith a copy of this process on February 1, 2019. Section III.a. of the

Commission’s written submission process states in pertinent part that:

The Appointing Authority will be required to file the initial submission in connection with an appeal. Said submission shall be filed within twenty-one (21) calendar days of [the] date of the Notice of Institution of Case received from the Civil Service Commission. The Appointing Authority’s submission should include the following: 1. A notarized statement from the Appointing Authority or his/her designee setting forth the specific reasons for the action which is the subject matter of the appeal. 2. Copies of any pertinent department/division work rules, standards of performance or regulations pertinent to the disciplinary action . . . including rules, standards or regulations allegedly violated by the appellant. 3. Notarized statements from witness and/or individuals (including but not limited to supervisors) with personal knowledge of the basis for the disciplinary action . . . being appealed.

(Emphasis added). Chief Jenkerson filed the initial submission statement in support of the 15-day

suspension; however, the statement was not notarized. While Chief Jenkerson included internal

emails, request for discipline forms, and memoranda from the paramedic supervisor, EMS

deputy chief, and medical officer to support his submission, he provided no sworn statements

from these or other witnesses. Smith submitted her notarized response under Section III.b. of the

3 written submission process, 1 raising the issue that Chief Jenkerson’s statement was not notarized.

Chief Jenkerson then filed his rebuttal, which was not notarized, and finally, Smith filed her

reply, again pointing out that the appointing authority’s statements were not notarized.

The Commission found Smith was suspended from her job for good and just cause, and

upheld the 15-day suspension. Smith then filed a petition for judicial review in the Circuit Court

of the City of St. Louis. The circuit court found that “[w]hile not notarized, Chief Jenkerson’s

statement was supported by ample evidence.” The court concluded, inter alia, that the

Commission’s decision was supported by competent and substantial evidence upon the whole

record, and was not made upon unlawful procedure or without a fair trial. The court affirmed the

Commission’s decision suspending Smith for 15 days. Smith appeals.

Standard of Review

We review the decision of the Civil Service Commission rather than the circuit court’s

decision. Section 536.140.2 RSMo. (2016); 2 Stone v. Mo. Dep’t of Health and Senior Services,

350 S.W.3d 14, 19 (Mo. banc 2011). The Commission is an “agency” for purposes of the

Missouri Administrative Procedure Act (“MAPA”), and so is required to follow the MAPA’s

procedure. Sections 536.010–536.150; Sapp v. City of St. Louis, 320 S.W.3d 159, 164 (Mo. App.

1 Section III.b. states in pertinent part: A complete copy of the Appointing Authority’s submission will be forwarded to the Appellant. The Appellant shall respond to the Appointing Authority’s submission within twenty-one (21) calendar days. The Appellant’s submission should include the following: 1. A notarized statement from the Appellant setting forth the specific reasons for appealing the decision. 2.

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Bluebook (online)
Elizabeth Smith v. City of St. Louis, Counsel Stack Legal Research, https://law.counselstack.com/opinion/elizabeth-smith-v-city-of-st-louis-moctapp-2021.