Griffin v. Police Officer Standards and Training Commission

CourtSuperior Court of Delaware
DecidedJanuary 31, 2025
DocketK24A-04-006 NEP
StatusPublished

This text of Griffin v. Police Officer Standards and Training Commission (Griffin v. Police Officer Standards and Training Commission) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Griffin v. Police Officer Standards and Training Commission, (Del. Ct. App. 2025).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

ANTHONY GRIFFIN, ) ) Appellant, ) ) v. ) C.A. No. K24A-04-006 NEP ) POLICE OFFICER STANDARDS ) AND TRAINING COMMISSION, ) ) Appellee. )

Submitted: November 6, 2024 Decided: January 31, 2025

OPINION

Upon Appeal from the Decision of the Police Officer Standards and Training Commission

AFFIRMED

James E. Liguori, Esquire, and Gregory A. Morris, Esquire, Liguori & Morris, Dover, Delaware, Attorneys for the Appellant.

Joseph C. Handlon, Deputy Attorney General, Department of Justice, Wilmington, Delaware, Attorney for the Appellee.

Primos, J. Former Dover Police Department corporal Anthony Griffin appeals the decision of the Police Officer Standards and Training Commission (“POST”) to revoke his certification as a law enforcement officer. Griffin argues that this case should be remanded because the record is insufficient for this Court’s review and that, if the Court nonetheless considers the substance of the appeal, POST’s decision should be reversed because it violated his due process rights. The Court today holds that the record is sufficient for appellate review and that POST did not violate Griffin’s due process rights. Because Griffin’s procedural arguments fail, the Court considers the merits of POST’s decision and concludes that it was supported by substantial evidence and did not rest on any errors of law. Therefore, the Court AFFIRMS POST’s decision to decertify Griffin.

2 I. BACKGROUND 1 A. The Decertification Process Title 11, Chapter 92 of the Delaware Code, commonly called the “Law Enforcement Officer’s Bill of Rights” (“LEOBOR”), generally requires an administrative hearing before an officer may be suspended or terminated.2 If an officer has received a LEOBOR hearing and has been “discharged from employment with a law-enforcement agency for a breach of internal discipline,” POST 3 must, by statute, either suspend or revoke that officer’s certification.4 An officer whose

1 Citations in the form of “D.I. ___” refer to docket items. Citations in the form of “B.D. ___” refer to the March 5, 2024, written decision of the three-member hearing board appointed by POST (the “Board”). Citations in the form of “Ex. ___” refer to exhibits introduced by either Griffin or the City of Dover before the Board. At the Board hearing, the City of Dover initially produced exhibits marked A–G, which are inaccurately lettered in the Certification of Record’s table of contents because one exhibit (Exhibit D, labeled “Notice of Disciplinary Action”) is omitted from the list of exhibits. See Certification of Record (D.I. 4); Police Officer Standards and Training Comm’n Board Hearing Audio Recording (hereinafter “Board Audio”) at 0:15. For purposes of this Opinion, the Court uses the exhibit letters and numbers used by the hearing Board (rather than those in the Certification), which are, with one exception, accurately stated in an exhibit list prepared by Stephanie J. Ballard, Esq., counsel for the City of Dover. This exhibit list is attached to the Certification. The one omission from Ms. Ballard’s list is Exhibit H, Griffin’s disciplinary history, which was admitted at the hearing but not previously designated. See Board Audio at 52:25. At the Board hearing, Griffin presented three exhibits, numbered 1–3, see Board Audio at 0:45. These exhibits were, respectively, a November 16 Notice of Disposition of Complaint, a February 13 employment offer letter from the Cheswold Police Department, and an October 27 letter from DELJIS informing Griffin that his access to that system had not been revoked. Though not referenced as defense exhibits in the Certification of Record, each of these documents is reproduced therein. With the exception of the letter from the Cheswold Police Department (appended to the LEOBOR board’s decision), each of Griffin’s Board exhibits is identically reproduced in the appendix to his Opening Brief. The Court is cognizant that this is only the second appeal from a POST decertification. However, it should be noted that the Court’s review process would have been substantially aided had it been furnished with a usable transcript, had the record been bound together and consecutively paginated for easier reference in this Opinion, and had the exhibits presented to the Board been marked and presented in order with accurate and complete identification in the Certification’s table of contents. 2 See 11 Del. C. § 9203. 3 POST is a seventeen-member administrative body with broad authorities to, among other things, establish and certify the requirements for police officers in the State of Delaware. See generally 11 Del. C. § 8402–8404. 4 See 11 Del. C. § 8404(a)(4)e. 3 certification has been revoked has “no authority to enforce the laws of the State.” 5 The Delaware Code also sets forth the process by which POST shall determine that an officer has received a LEOBOR hearing and been discharged, and by which POST shall thereafter decide between decertification and suspension of that officer.6 Per the Code, the chairperson selects three members of POST to sit as a board and hear evidence.7 This hearing is conducted in accordance with the Delaware Administrative Procedures Act. 8 Upon conclusion of the board hearing, the board submits its written findings and recommendations to the full POST for consideration and a vote.9 Adverse rulings may be appealed to this Court. 10 This case concerns such an appeal. B. Statement Of Facts The material facts underlying this appeal are undisputed. On August 26, 2020, Anthony Griffin and other Dover Police Department officers responded to a domestic violence call in the city.11 Griffin drove the female participant in the incident to the police station for processing. 12 The woman was considered both a victim and a suspect because the violence was apparently reciprocal. 13 After the woman was released, Griffin drove her home, and she volunteered her phone number. 14

5 11 Del C. § 8410(a). 6 See 11 Del. C. § 8404A (“In all situations where the provisions of § 8404(a)(4) or § 8410(b) of this title are to be applied to or invoked against any agency or individuals, that agency or individual shall be entitled to a hearing in the manner prescribed herein[.]”). 7 11 Del. C. § 8404A(1). 8 11 Del. C. § 8404A(4). 9 11 Del. C. § 8404A(2). 10 11 Del. C. § 8404A(3). 11 B.D. 3; LEISS report 50-20-21210 – 8/6/20 Domestic Incident (hereinafter “Domestic Incident Rep.) (Ex. F). 12 B.D. 3; Domestic Incident Rep. (Ex. F). 13 B.D. 6, Domestic Incident Rep. (Ex. F). 14 B.D. 3; Decision of Crim. Just. Council Hearing Bd. (hereinafter “LEOBOR Bd. Decision”) (Ex. C) at 3. 4 Shortly before the end of Griffin’s shift on August 26, the woman texted him for the first time.15 Per the Board, “the text messages became sexually explicit” almost immediately, and featured “a video of the woman dancing suggestively (‘twerking’) and . . . a photograph of [Griffin’s] . . . genitalia.”16 Griffin’s texts with the woman also directly implicated her pending criminal prosecution. The woman expressed concerns that the prosecution would hinder her career.17 Griffin assured the woman that her case would be dropped. 18 In February 2023, Griffin’s photograph was included in a Dover Police Department Facebook post recognizing the Department’s school resource officers.19 The man involved in the August 26, 2020, domestic violence incident (the “Complainant”) became aware of this post (and Griffin’s continued employment) and complained to the Department.20 As a result, Dover Police Lieutenant Kevin Streadwick (the “I.A. Investigator”) conducted an internal affairs investigation into the incident.21 In the course of this investigation, the I.A. Investigator interviewed both the Complainant and the woman.22 The woman confirmed the exchange of texts and photographs.23 Griffin was fully cooperative with the I.A.

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Griffin v. Police Officer Standards and Training Commission, Counsel Stack Legal Research, https://law.counselstack.com/opinion/griffin-v-police-officer-standards-and-training-commission-delsuperct-2025.