James Cunningham v. the City of New Orleans & the New Orleans Police Department

CourtLouisiana Court of Appeal
DecidedMarch 30, 2022
Docket2021-CA-0532
StatusPublished

This text of James Cunningham v. the City of New Orleans & the New Orleans Police Department (James Cunningham v. the City of New Orleans & the New Orleans Police Department) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Cunningham v. the City of New Orleans & the New Orleans Police Department, (La. Ct. App. 2022).

Opinion

JAMES CUNNINGHAM * NO. 2021-CA-0532

VERSUS * COURT OF APPEAL THE CITY OF NEW ORLEANS * & THE NEW ORLEANS FOURTH CIRCUIT POLICE DEPARTMENT * STATE OF LOUISIANA *******

APPEAL FROM CIVIL DISTRICT COURT, ORLEANS PARISH NO. 2017-02521, DIVISION “A” Honorable Ellen M. Hazeur, Judge ****** Judge Dale N. Atkins ****** (Court composed of Chief Judge Terri F. Love, Judge Dale N. Atkins, Judge Pro Tempore Lynn M. Luker)

Frank G. DeSalvo Shannon R. Bourgeois FRANK G. DeSALVO, APLC 739 Baronne Street New Orleans, LA 70113

COUNSEL FOR PLAINTIFF/APPELLANT

Daniel T. Smith, Assistant City Attorney Isaka R. Williams, Assistant City Attorney Corwin M. St. Raymond, Deputy Assistant City Attorney Churita H. Hansell, Chief Deputy City Attorney Donesia D. Turner, City Attorney 1300 Perdido Street City Hall - Room 5E-03 New Orleans, LA 70112

COUNSEL FOR DEFENDANTS/APPELLEES

AFFIRMED MARCH 30, 2022 DNA TFL LML

This tort appeal arises from a civil service matter in which the New Orleans

Police Department (hereinafter “NOPD”) brought disciplinary proceedings against

a police officer after his involvement in a domestic dispute. Appellant, James

Cunningham (hereinafter “Mr. Cunningham”1), appeals the trial court’s October

15, 2020 judgment, which granted the Third Exception of No Cause of Action filed

by Appellee, the City of New Orleans (hereinafter “City”), and by some City

employees, namely Shaun Ferguson, Michael Harrison, Arlen Barnes, Derek Frick,

Arlinda Westbrook, and Shontee Smothers, and dismissed Mr. Cunningham’s

Petition for Damages with prejudice. For the following reasons, we affirm the trial

court’s judgment.

1 As discussed more fully throughout this Opinion, James Cunningham served as an officer with NOPD at the time of the incident giving rise to this suit; however, based on the record before this Court, it is unclear whether he is presently employed as a police officer with NOPD or with any other police department. Accordingly, this Opinion will refer to James Cunningham as “Mr. Cunningham” rather than “Officer Cunningham.”

1 FACTUAL BACKGROUND AND PROCEDURAL HISTORY

Petition for Damages

After he was arrested following a domestic dispute that occurred on January

13, 2015, NOPD commenced disciplinary proceedings against Mr. Cunningham,

who was an off-duty police officer with NOPD at the time of the dispute.2 On

March 2, 2016, NOPD conducted Mr. Cunningham’s disciplinary hearing relating

to the domestic dispute, but he did not attend the hearing.3 On March 17, 2016,

NOPD terminated Mr. Cunningham. He filed an appeal of his termination to the

Civil Service Commission of the City of New Orleans (hereinafter “Commission”)

on April 5, 2016.

Additionally, after his termination, Mr. Cunningham initiated this legal

proceeding with the filing of a Petition for Damages (hereinafter “Petition”) in the

Civil District Court for the Parish of Orleans on March 17, 2017. In the Petition,

he named the City and NOPD as defendants. Mr. Cunningham stated that his

termination was discriminatory; in violation of La. R.S. 23:332;4 and retaliatory.

2 Because the facts of the incident are not relevant to this appeal, instead of reproducing them in this Opinion, we adopt the factual background produced in this Court’s Opinion in response to Mr. Cunningham’s prior appeal. See Cunningham v. New Orleans Police Dep’t, 2018-0095 (La. App. 4 Cir. 10/10/18), 257 So.3d 801. 3 In briefing to this Court, Mr. Cunningham and the City dispute the reason for his absence at the March 2, 2016 disciplinary hearing. Mr. Cunningham alleges that he missed the hearing because he was on authorized medical leave. However, the City notes that the Civil Service Commission’s Judgment in this matter ultimately concluded that Mr. Cunningham declined to attend the hearing upon advice of his counsel to invoke his Fifth Amendment right against self-incrimination because criminal charges stemming from the January 13, 2015 domestic dispute were still pending against Mr. Cunningham. 4 Louisiana Revised Statute 23:332 pertains to “[i]ntentional discrimination in employment.”

2 Mr. Cunningham also asserted that, as a result of his wrongful termination, he

suffered “los[t] wages, fright, fear, mental anguish, emotional distress and all

damages as are reasonable under the circumstances.” Further, he alleged that he

suffered injuries as a result of the City and NOPD unlawfully confining his person.

Mr. Cunningham listed these injuries as including physical injuries, mental

suffering, loss of earnings, injury to his reputation, and deprivation of any right

caused by the loss of liberty.

First Exception of No Cause of Action

In response to the Petition, on May 19, 2017, the City and NOPD filed a

Declinatory Exception of Lack of Jurisdiction;5 a Peremptory Exception of No

Cause of Action (hereinafter “First Exception of No Cause of Action”); 6 and a

Peremptory Exception of Prescription.7 However, the City agreed to continue

these exceptions pending the outcome of Mr. Cunningham’s appeal to the

Commission.

Civil Service Commission Hearing and Judgment

On June 29, 2017, the Commission conducted a hearing regarding Mr.

Cunningham’s appeal of his termination, and Mr. Cunningham was present at the

hearing. In his appeal to the Commission, Mr. Cunningham contended that his

5 In the Exception of Lack of Jurisdiction, the City and NOPD argued that the trial court “lacked subject matter jurisdiction over [Mr. Cunningham]’s claims for damages resulting from his allegedly wrongful termination, which can only properly be resolved by the [Commission].” 6 In the First Exception of No Cause of Action, the City and NOPD argued that Mr. Cunningham failed to allege well-pleaded facts to support a cause of action for employment discrimination or retaliation. 7 In the Exception of Prescription, the City and NOPD argued that Mr. Cunningham’s claims resulting from his arrest prescribed one year after his arrest and detention and had prescribed by the date Mr. Cunningham filed his Petition on March 17, 2017.

3 termination was arbitrary, unreasonable, and without any basis in fact or law.

Additionally, at the June 29, 2017 hearing, Mr. Cunningham argued that his due

process rights had been violated because he had not received a meaningful

opportunity to respond to the disciplinary allegations against him prior to his

termination.

The Commission, in an October 17, 2017 judgment, upheld Mr.

Cunningham’s termination from NOPD. Further, the Commission found that Mr.

Cunningham’s due process rights had not been violated during his disciplinary

proceedings. Rather, the Commission determined that Mr. Cunningham decided

not to attend his March 2, 2016 disciplinary hearing on advice of counsel because

he wanted to invoke his Fifth Amendment right against self-incrimination as

criminal charges stemming from the domestic dispute were still pending against

him. The Commission concluded that Mr. Cunningham declining to attend the

disciplinary hearing did not change the fact that the City presented Mr.

Cunningham with an opportunity to be heard and did not violate his due process

rights.

On October 24, 2017, Mr. Cunningham filed a Notice of Appeal regarding

the Commission’s October 17, 2017 judgment. In his Notice of Appeal, Mr.

Cunningham asserted that “[t]he [Commission] erred in denying [his] appeal.” The

matter proceeded before this Court.

Prior Appeal

Mr. Cunningham’s appeal of the Commission’s October 17, 2017 judgment

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