Fraternal Order of Police v. City of Yankton

949 N.W.2d 412, 2020 S.D. 52
CourtSouth Dakota Supreme Court
DecidedSeptember 16, 2020
Docket29203
StatusPublished
Cited by2 cases

This text of 949 N.W.2d 412 (Fraternal Order of Police v. City of Yankton) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fraternal Order of Police v. City of Yankton, 949 N.W.2d 412, 2020 S.D. 52 (S.D. 2020).

Opinion

#29203-r-DG 2020 S.D. 52

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

THE FRATERNAL ORDER OF POLICE, VERMILLION LODGE NO. 19, YANKTON POLICE OFFICERS’ ASSOCIATION, Appellees,

v.

CITY OF YANKTON, SOUTH DAKOTA, Appellant.

APPEAL FROM THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT YANKTON COUNTY, SOUTH DAKOTA

THE HONORABLE CHERYLE GERING Judge

THOMAS K. WILKA SARA E. SCHROEDER of Hagen, Wilka & Archer, LLP Sioux Falls, South Dakota Attorneys for appellees.

A. STEVENSON BOGUE of McGrath, North, Mullin & Kratz, P.C. LLO Omaha, Nebraska

ROSS K. DEN HERDER of Den Herder & Hosmer Law Office Yankton, South Dakota Attorneys for appellant.

CONSIDERED ON BRIEFS MAY 27, 2020 OPINION FILED 09/16/20 #29203

GILBERTSON, Chief Justice

[¶1.] The Department of Labor determined that sergeants in the Yankton

Police Department are ineligible for membership in a collective bargaining unit

because they have authority to hire or effectively recommend hiring decisions. The

circuit court reversed that decision on appeal, determining sergeants did not have

that authority. The City of Yankton appeals the circuit court’s decision. We

reverse.

Facts and Procedural History

[¶2.] In November 2017, the City of Yankton (the City) filed a Request for

Unit Determination with the Department of Labor (the Department) to define the

membership of the collective bargaining unit requested by the Fraternal Order of

Police, Vermillion Lodge No. 19, Yankton Police Officers’ Association (the FOP).

The FOP requested that its members include “[f]ull time members of the Yankton

Police Department holding job titles of Police Sergeant, Police Corporal, Police

Detective/Investigator, and Police Officers” and exclude “Chief of Police, Police

Lieutenant, and all other civilian non-sworn employees.” The City requested that

Police Sergeants and Police Corporals also be excluded and argued that officers

currently commissioned and enlisted in the South Dakota National Guard were

similarly ineligible for membership.

[¶3.] Under SDCL 3-18-1(2), public employees eligible for membership in

collective bargaining units do not include:

public employees having authority in the interest of the public employer to hire, transfer, suspend, layoff, recall, promote, discharge, assign, reward, or discipline other public employees, or the responsibility to direct them, or to adjust their grievances,

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or to effectively recommend such action, if in connection with the foregoing, the exercise of such authority is not of a merely routine or clerical nature, but requires the use of independent judgment[.]

[¶4.] The Department held a hearing in May 2018, at which Chief of Police

Brian Paulsen, Sergeant Jason Foote, Sergeant Javier Murguia, Sergeant Monty

Rothenberger, and Lieutenant Michael Burgeson (all members of the Yankton

Police Department) testified. Chief Paulsen testified that the Yankton Police

Department (YPD) rank structure consisted of the Chief of Police, two lieutenants,

four sergeants, one corporal, and multiple patrol and investigations officers at that

time, but he explained that the corporal rank was being phased out. He also

described the hiring process at the YPD, which consists of a written standardized

test with an essay portion graded by a lieutenant, a timed obstacle course, an

informal interview with one sergeant and one patrol officer, a formal interview with

a panel of four sergeants and one lieutenant, and a background check.

[¶5.] The formal interview panel scores candidates based on a point system

of one through five. The panel members are required to give scores no more than

two points apart from each other, and if points differ by too much, they discuss how

to change the scores to fit the two-point rule. The candidates are ranked by their

scores, and any tie in scores is broken by the candidate with the better obstacle

course time. The ranked list then goes to the Chief of Police, whose practice is to go

down the list making conditional offers of employment, although Chief Paulsen was

unaware of any city policy dictating that the Chief must follow the list. The

employment offers are conditioned upon the passage of a background check.

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[¶6.] Chief Paulsen also testified to the powers given to sergeants.

Sergeants are involved in transferring employees from patrol to investigations,

scheduling shifts, and assigning squads, though a lieutenant or the Chief of Police

has final approval. Sergeants do not have the power to lay off or recall a laid off

employee. All members of the YPD can submit nominations for Officer of the Year,

an award ultimately chosen by the previous year’s winner; and all members can

recommend commendations. Sergeants first complete officer evaluations. Then, the

evaluations pass to lieutenants and to the Chief of Police for additional comments.

[¶7.] Chief Paulsen testified that there are times when a patrol officer is the

highest-ranking officer on duty and in charge in the same way that a sergeant

would be as the highest-ranking officer present. The Chief of Police and lieutenants

typically work 8:00 a.m. to 5:00 p.m. Monday through Friday, so sergeants are the

commanding officer approximately 128 hours per week. Lieutenant Burgeson

estimated that a patrol officer is the commanding officer on duty around 15 percent

of the year.

[¶8.] Sergeant Foote testified that as a sergeant there are times when he is

the commanding officer on duty and that he must notify lieutenants or the Chief of

Police when a serious or major incident happens. He also testified that a lieutenant

could ask him to change his comments on officer evaluations, but it had never

happened. Sergeant Murguia testified that he believed approximately 16 hours of

every two-week period would have no sergeant on duty.

[¶9.] Sergeant Rothenberger testified about his involvement in most aspects

of YPD’s interview process and described the process similarly to Chief Paulsen’s

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description. He explained that the informal interview, which determines which

candidates move on to the formal interview, involves equal input from the sergeant

and patrol officer based on their gut feelings. He also testified that all sergeants

schedule their squads in their own way.

[¶10.] The parties submitted post-hearing briefs in which the FOP argued the

sergeant’s role under SDCL 3-18-1(2) is merely routine and/or clerical and does not

require the exercise of independent judgment. The City countered that Chief

Paulsen’s testimony made clear that sergeants play a large part in YPD’s hiring

process. The Department filed its order on September 5, 2018, deciding that

National Guard members and corporals are not precluded from membership in the

bargaining unit, but sergeants are precluded from membership. The Department

found while sergeants do not possess authority for most of the provisions of SDCL 3-

18-1(2), they have authority to hire or effectively recommend hiring.

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949 N.W.2d 412, 2020 S.D. 52, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fraternal-order-of-police-v-city-of-yankton-sd-2020.