Eric Dale v. Marshall Township

CourtMichigan Court of Appeals
DecidedSeptember 5, 2024
Docket364971
StatusUnpublished

This text of Eric Dale v. Marshall Township (Eric Dale v. Marshall Township) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eric Dale v. Marshall Township, (Mich. Ct. App. 2024).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

ERIC DALE, UNPUBLISHED September 5, 2024 Plaintiff-Appellant/Cross-Appellee,

v No. 364971 Calhoun Circuit Court MARSHALL TOWNSHIP, LC No. 2021-000571-CZ

Defendant-Appellee/Cross-Appellant.

Before: GARRETT, P.J., and LETICA and MALDONADO, JJ.

PER CURIAM.

Plaintiff-appellant/cross-appellee, Eric Dale, filed this action against defendant- appellee/cross-appellant, Marshall Township, and claimed that the township terminated his employment in violation of The Whistleblowers’ Protection Act (WPA), MCL 15.361 et seq. Dale served as a firefighter for the township for nearly 20 years, and also served as an assistant fire chief, when the township fire board voted to terminate Dale’s employment based on the recommendation of township fire chief, Steven Riggs. In the weeks and months before his termination, Dale reported various concerns to township leaders about problems within the fire department, the most serious of which involved the legitimacy of certain payments Chief Riggs made to his sons, who also worked for the fire department. Because we hold that Dale established a genuine issue of material fact that he was both engaged in a protected activity and that Marshall Township terminated him because of that activity, we reverse the trial court’s grant of summary disposition to the township under MCR 2.116(C)(10). We disagree with Marshall Township’s contention on cross-appeal that the statute of limitations barred Dale’s complaint, and we also disagree with Dale’s request that the case be remanded to a different judge in a different circuit court. For these reasons, we affirm in part, reverse in part, and remand to the same court for further proceedings.

-1- I. FACTUAL AND PROCEDURAL HISTORY

A. DALE’S POSITION AND CONCERNS

The Marshall Township Fire Department hired Dale as a firefighter in 2001. Chief Riggs served as the fire chief and, in 2015 or 2016, Chief Riggs appointed his son Jay Riggs and Dale to share the job of assistant fire chief. Chief Riggs’s other son, Josh Riggs, also worked as a firefighter for the township’s fire department. In 2019, Jay accepted a job as a full-time firefighter for the city of Marshall while he continued to serve as an officer for the township fire department. The township had a mutual aid agreement with the city of Marshall and other municipalities in Calhoun County. The agreement allowed fire departments to respond to and assist with incident calls in other jurisdictions. According to Dale, although no written policy prohibited it, there was a long-standing rule that township fire department officers could not also work for fire departments with which the township had mutual aid agreements.

After Jay began working for the city fire department, Dale expressed concerns about a violation of the dual employment rule to Chief Riggs and members of the fire and township boards. Dale also expressed concerns that Jay received compensation from both the city and township when he responded to incident calls under the mutual aid agreement. According to Dale, when Jay would arrive at a mutual aid incident as a city firefighter, he would instruct someone from the township fire department to also put his name down on the township run sheet so that he would get paid by both the city and township for working the same incident. Dale also asserted that the township paid Jay to participate in township fire department training while Jay was on duty at the city’s fire department.

From Dale’s perspective, Jay’s positions as an officer of the township fire department and a city firefighter also caused safety concerns and confusion at fire scenes. Dale testified that, when Jay responded to a fire as a member of the city’s fire department in June 2020, he directed a township firefighter to use a city-owned self-contained breathing apparatus in an active structure fire even though the township firefighter had no training on how to use it. Dale asserted that, at another incident in August 2020, Chief Riggs turned over control of a scene to Jay because Chief Riggs could not hear radio traffic, even though Jay had responded to the call as a non-officer, city firefighter. According to Dale, because he was an assistant fire chief, firefighters expressed frustration to him about Jay assuming this authority, and he further noted that, despite safety concerns about Chief Riggs’s hearing problems, the chief did not receive annual hearing tests required for firefighters. Dale believed for a time that this violated the National Fire Protection Association standards adopted in the Michigan Administrative Code.

Dale also observed that Chief Riggs paid his sons to do administrative tasks that the township paid Chief Riggs to perform and that he did not pay other firefighters for doing work in addition to their fire runs and training hours. Dale testified that Chief Riggs also paid one or both of his sons for training and fire runs that never occurred or in which they did not participate as township firefighters. In Dale’s opinion, it violated the law for Jay to receive double pay and for Chief Riggs to pay Jay and Josh additional compensation from the fire department.

Dale spoke to Chief Riggs about Jay working as a township fire department officer while also working as a full-time firefighter for the city. Dale testified that Chief Riggs said he would

-2- speak to the fire board about it, but Dale did not think he did so. Dale also aired his concerns to township board member Ronald Quinn, fire board members Paul Kiessling and Jefferey Albaugh, and township supervisor David Bosserd. Quinn discussed Dale’s concerns with Albaugh and Bosserd. Quinn told Dale that he believed the fire board should hear Dale’s concerns.

At a fire department officers meeting in February 2020, Dale and Lieutenant William Cohoe expressed concerns to Chief Riggs about training opportunities, inappropriate language in front of female firefighters, failure to hold annual meetings and reviews, and a lack of transparency about department expenditures and payroll. According to Dale, Chief Riggs declined to address the issues.

B. FIRE DEPARTMENT MEETING AND DISCUSSIONS WITH TOWNSHIP OFFICIALS

At a fire department meeting on September 24, 2020, Chief Riggs announced that a fire chief from another fire department called him and said that a Marshall Township firefighter made negative comments about the other fire department. During discovery, an audio recording of the meeting was produced and transcribed. As Chief Riggs explained at the meeting:

[The other fire chief] didn’t know who. I don’t know who . . . half our department is here, it might be one of the people who are not here but, we’re all in this together, every department is doing the best that they can do. That kind of behavior is not going to be tolerated by me. If I get another call or get a name . . . [.] If anyone has an issue with any other department, come see me and me alone and tell me and I will handle it. But if I hear any more shit going on and I find who it is, they will not be on this department.

Dale asked Chief Riggs if the complaint came from Marengo or Fredonia, which are townships. Chief Riggs declined to name the department and said that it did not matter. Dale responded that it did matter and that he knew that Marengo’s fire department was unhappy because Chief Riggs made a comment to Marengo firefighters at a semi-truck fire. Chief Riggs asked Dale why he did not tell him about it and Dale replied that Marengo’s fire chief was going to call Chief Riggs to discuss it.

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Bluebook (online)
Eric Dale v. Marshall Township, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eric-dale-v-marshall-township-michctapp-2024.