Hartley v. Fine

780 F.2d 1383
CourtCourt of Appeals for the Eighth Circuit
DecidedDecember 31, 1985
DocketNos. 84-1789, 84-2441
StatusPublished
Cited by8 cases

This text of 780 F.2d 1383 (Hartley v. Fine) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hartley v. Fine, 780 F.2d 1383 (8th Cir. 1985).

Opinion

BRIGHT, Senior Circuit Judge.

Jay K. Hartley, former bureau manager of the Missouri Department of Revenue, brought this civil rights action under 42 U.S.C. § 1983 seeking reinstatement and damages from his supervisors and a state senator (John T. Russell). Hartley alleges that the defendants terminated his employment for partisan political reasons in violation of his first amendment rights. After a trial in which the jury denied Hartley damages, and the district court1 denied his claim for the equitable relief of reinstate[1385]*1385ment, Hartley brings this appeal. For reversal, Hartley contends that the district court erred in: (1) denying his claim for equitable relief based on a violation of procedural due process; (2) refusing to instruct the jury that it should hold for Hart-ley if it concluded that political affiliation was a “motivating factor” in the discharge; (3) instructing the jury that a good faith defense was available to defendants; and (4) instructing the jury that it must rule for the defendants if Hartley would have been terminated regardless of his political affiliation. In addition to seeking an affirmance on the merits of the judgment, Senator Russell separately appeals from the judgment of the district court, 595 F.Supp. 83, denying his motion for summary judgment based on legislative immunity. We affirm.

I. BACKGROUND.

Hartley brought this civil rights action against: the Director of the Division of Taxation and Collection, Camden R. Fine, who terminated Hartley; the former Director of Revenue, Ray S. James, who allegedly ordered the dismissal; the Director of Revenue (who at the time of suit was Richard J. King and who has been succeeded by Paul S. McNeill); and Missouri State Senator John T. Russell.

Hartley, a Democrat, alleged that he was discharged from his position as manager of the Compliance Bureau of the Missouri Department of Revenue for partisan political reasons. Essentially, Hartley claimed that his discharge was the result of a letter from Senator Russell, a Republican, to Ray James, a Republican, in which Russell stated his belief that problems in the Compliance Bureau would not be resolved until Hartley was removed or transferred. Hartley’s supervisors contended that Hart-ley’s job performance was unacceptable and he was discharged for just cause.

Prior to his discharge, Hartley received no opportunity to respond to the termination decision. After his termination, Hartley sought to overturn his dismissal under Missouri statutory procedures. Hartley contested his discharge before the Missouri Personnel Advisory Board. After a hearing, the Board determined that under Missouri law, Hartley had no right to the Board’s post termination procedures.

Hartley then filed this civil rights suit in the United States District Court. At trial, Hartley contended that he held a non-poli-cymaking position and, therefore, could not be dismissed for political reasons under Branti v. Finkel, 445 U.S. 507, 100 S.Ct. 1287, 63 L.Ed.2d 574 (1980) and Elrod v. Burns, 427 U.S. 347, 96 S.Ct. 2673, 49 L.Ed.2d 547 (1976). By its verdict, the jury rejected Hartley’s claim that political reasons contributed to the discharge. In denying Hartley’s request for the equitable relief of reinstatement, the district court concluded that Hartley’s “employment was terminated solely because of his job performance.”

II. DISCUSSION.

A. Procedural Due Process.

The record makes clear that Hartley received no pretermination process, and that under Missouri law he could avail himself of no post termination procedures. Although at trial the district court concluded that Hartley held a non-policymaking position for federal constitutional purposes, the Missouri Personnel Advisory Board determined that for state law purposes Hartley held a policymaking position and, as such, was not entitled to a statutory post-discharge hearing. Hartley contends that under Missouri law he had a property right in continued employment, and, that as a matter of law, the State deprived him of this property right without due process. We disagree.

Although it appears that Hartley failed to raise this contention below, we will address it here because it is raised as a matter of law. Analysis of the Missouri statutes discloses that, as a non-merit system employee, Hartley possessed no property right in continued employment. Mo. Rev.Stat. § 36.030(1) (1981). As such, Hartley could not obtain statutory procedures accorded merit system employees un[1386]*1386der Mo.Rev.Stat. § 36.390(5) (1981).2 Hart-ley argues, however, that under Mo.Rev. Stat. § 36.390(7) and (8) he was entitled to substantially the same procedures due merit system employees. Hartley cites no cases in support of this contention. In fact, subsections (7) and (8) of section 36.-390 do not explicitly confer on Hartley any such right to post termination procedure.3 In addition, the only record evidence relating to this contention is the Missouri Personnel Advisory Board’s decision that Hart-ley held a policymaking position exempt from the requirement of post termination process available to state merit employees. Because Hartley failed to demonstrate that he had a property interest in his continued employment or that he was statutorily entitled to procedural due process regarding his termination, we reject this contention.

B. Jury Instructions.

1. The Propriety of the Mt. Healthy City School District Board of Education v. Doyle Instruction.

Instructions No. 6 and 84 directed the jury to return a verdict for Hartley, in [1387]*1387part, if Hartley’s “political affiliation was a substantial factor” in the decision to terminate his employment. Hartley asserts that the district court erred in refusing to add that the verdict should be for Hartley if his political affiliation was a “motivating factor” in the termination decision. Hart-ley contends that the “motivating factor” language was required by the Supreme Court’s decision in Mt. Healthy City School District Board of Education v. Doyle, 429 U.S. 274, 97 S.Ct. 568, 50 L.Ed.2d 471 (1977). However, in Mt. Healthy, the Supreme Court stated that “the burden was properly placed upon respondent to show that his conduct was constitutionally protected, and that this conduct was a ‘substantial factor’ — or, to put it in other words, that it was a ‘motivating factor’ in the * * * decision not to rehire him.” Id. at 287, 97 S.Ct. at 576 (footnote omitted). From this excerpt it is clear that in Mt. Healthy the Supreme Court determined that the terms “motivating” and “substantial” could be used interchangeably in the context of a claim for retaliatory discharge for the exercise of the employee’s constitutional rights. Thus, in the instant case, the district court did not err in refusing to submit both these terms in the instructions to the jury.

2. Propriety of the Qualified Immunity Instructions.

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780 F.2d 1383, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hartley-v-fine-ca8-1985.