JEFFERSON COUNTY, KENTUCKY v. Zaring

91 S.W.3d 583, 2002 Ky. LEXIS 248, 2002 WL 31887766
CourtKentucky Supreme Court
DecidedDecember 19, 2002
Docket2000-SC-0596-DG
StatusPublished
Cited by24 cases

This text of 91 S.W.3d 583 (JEFFERSON COUNTY, KENTUCKY v. Zaring) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
JEFFERSON COUNTY, KENTUCKY v. Zaring, 91 S.W.3d 583, 2002 Ky. LEXIS 248, 2002 WL 31887766 (Ky. 2002).

Opinions

COOPER, Justice.

This is a civil action for damages brought pursuant to KRS 344.450 of the Kentucky Civil Rights Act (KCRA) alleging reverse racial discrimination in employment. KRS 344.040. A Jefferson Circuit Court jury awarded damages to Jefferson County Police Department (JCPD) Sergeants Leroy Zaring and Tracy Hord because, in November 1994, former JCPD Chief Leon Jones recommended that JCPD Sergeants Thomas Dreher and James Smith be promoted to lieutenant but did not make similar recommendations with respect to Zaring and Hord, and because the Jefferson County Judge/Executive and the Jefferson Fiscal Court followed Jones’s recommendations. Zaring, Hord and Jones all are Caucasian males; Dreher and Smith are African-American males.

Jefferson Circuit Court Judge Ellen Ewing set aside the award of damages and entered a judgment NOV in favor of the Fiscal Court. The Court of Appeals reversed and ordered the verdict reinstated. We now reverse the Court of Appeals and reinstate the judgment NOV.

I. INTRODUCTION.

In Detroit Police Officers’Association v. Young, 608 F.2d 671 (6th Cir.1979),1 Judge Pierce Lively, writing for the Sixth Circuit Court of Appeals, chronicled the history and rationale of affirmative action as an operational requirement of local police departments.

The defense of operational requirements is claimed by the defendants to be an independent justification for the affirmative action plan. The basis of the claim is that improved law enforcement is a sufficiently important reason in itself for affirmative action.
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The argument ... is based on law enforcement experience and a number of studies conducted at the highest levels. E.g., National Advisory Commission on Criminal Justice Standards and Goals, Police (1973); National Commission on the Causes and Prevention of Violence, Final Report: To Establish Justice, To Insure Domestic Tranquility (1969); Report of the National Advisory Commission on Civil Disorders (1968); President’s Commission on Law Enforcement and Administration of Justice, Task Force Report: The Police (1967). As these reports emphasize, the relationship between government and citizens is seldom more visible, personal and important than in police-citizen contact. See To Establish Justice, supra at 145; Report on Civil Disorders, supra at 300 (New York Times Edition). It is critical to effective law enforcement that police receive public cooperation and support. Report on Civil Disorders, supra at 301; Task Force Report: The Police, supra at 144-45, 167; Police, supra at 330.
These national commissions recommended the recruitment of additional numbers of minority police officers as a means of improving community support and law enforcement effectiveness. In fact, the benefits of [African-American] officers were recognized as early as 1931 by the “Wickersham Commission.” Report on the Causes of Crime 242, Na[586]*586tional Commission of Law Observance and Enforcement (Vol.1,1931).
In 1967, a presidential commission stated the proposition offered by the defendants in this case:
In order to gain the general confidence and acceptance of a community, personnel within a police department should be representative of the community as a whole.
Task Force Report: The Police, supra at 167.
This need extends to the higher ranks in the police departments, such as the rank of sergeant involved in this case:
If minority groups are to feel that they are not policed entirely by a white police force, they must see that [African-American] or other minority officers participate in policymaking and other crucial decisions.
Id. at 172.
The presence of a mostly white police force in minority communities can be a “dangerous irritant” which can trigger, as it did in Detroit in 1967, a violent response. Report on Civil Disorders, supra at 315, 120; see also id. at 84-108 (chronology of events of 1967 Detroit civil disorders).
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The argument that police need more minority officers is not simply that blacks communicate better with blacks or that a police department should cater to the public’s desires. Rather, it is that effective crime prevention and solution depend heavily on the public support and cooperation which result only from public respect and confidence in the police. In short, the focus is not on the superior performance of minority officers, but on the public’s perception of law enforcement officials and institutions.

Id. at 695-96.

The Kentucky Civil Rights Act (KCRA) was enacted in 1966 to implement in Kentucky the Federal Civil Rights Act of 1964. 1966 Ky. Acts, ch. 2 Art. I, § 101; see KRS 344.020(1). Thus, the provisions of the KCRA are virtually identical to those of the Federal act. Mills v. Gibson Greetings, Inc., 872 F.Supp. 366, 371 (E.D.Ky.1994). For that reason, we held in Harker v. Federal Land Bank of Louisville, Ky., 679 S.W.2d 226 (1984), that “in this particular area we must consider the way the Federal act has been interpreted.” Id. at 229. In 1972, those provisions of Title VII of the 1964 Civil Rights Act that proscribe discrimination in employment were made applicable to states and municipalities. Equal Employment Opportunity Act of 1972 (EEOA), Pub.L. No. 92-261, 86 Stat. 103 (March 24, 1972); see 42 U.S.C. § 2000e(b). The rule of construction enunciated in Harker, supra, is especially applicable to KRS 344.040(1) since the definition of employment discrimination in that statute is almost identical to the definition of an “unlawful employment practice” in the EEOA. 42 U.S.C. § 2000e-2(a)(1). Conduct that violates KRS 344.040(1) almost certainly contravenes Title VII as well. Roy v. Russell County Ambulance Serv., 809 F.Supp. 517, 519 (W.D.Ky.1992). This fact tangentially implicates the principle enunciated in Chesapeake & O, Ry., Co. v. Martin, 283 U.S. 209, 51 S.Ct. 453, 75 L.Ed. 983 (1931), that an interpretation given to a federal statute by the United States Supreme Court is binding on state courts, “any state law, decision or rule to the contrary notwithstanding.” Id. at 220-21, 51 S.Ct. at 453.

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Bluebook (online)
91 S.W.3d 583, 2002 Ky. LEXIS 248, 2002 WL 31887766, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jefferson-county-kentucky-v-zaring-ky-2002.