John Keith Richard v. Lafayette Fire and Police Civil Service Board

CourtLouisiana Court of Appeal
DecidedApril 16, 2008
DocketCA-0007-1010
StatusUnknown

This text of John Keith Richard v. Lafayette Fire and Police Civil Service Board (John Keith Richard v. Lafayette Fire and Police Civil Service Board) 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
John Keith Richard v. Lafayette Fire and Police Civil Service Board, (La. Ct. App. 2008).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

07-1010

JOHN KEITH RICHARD

VERSUS

LAFAYETTE FIRE AND POLICE CIVIL SERVICE BOARD AND LAFAYETTE CONSOLIDATED GOVERNMENT

********** APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NO. 2006-3111 HONORABLE JOHN D. TRAHAN, DISTRICT JUDGE

**********

J. DAVID PAINTER

********** Court composed of Billy Howard Ezell, J. David Painter, and James T. Genovese, Judges.

REVERSED AND RENDERED.

William L. Goode 812 Johnston St. Lafayette, LA 70501 Counsel for Plaintiff-Appellant: John Keith Richard

M. Candace Hattan P.O. Drawer 91850 Lafayette, LA 70509 P.O. Box 13438 Counsel for Defendants-Appellees: Lafayette Municipal Fire and Police Civil Service Board

Michael P. Corry P.O. Box 51367 Lafayette, LA 70505 Counsel for Defendant-Appellee: Lafayette Consolidated Government PAINTER, Judge.

This case is before us for a review of the district court’s ruling on the appeal

of a decision of the Lafayette Fire and Police Civil Service Board (the Board)

affirming the termination of John Keith Richard on August 2, 2005.

FACTS

In June 2005, Richard was employed as a Lafayette City Policeman. He also

worked as security for Club 410, a bar/nightclub located in downtown Lafayette,

Louisiana. Also employed at Club 410 were Jason Galatas, another Lafayette City

Policeman, and Jason Segal. Segal allegedly told Galetas that his roommate, Marc

Cormier, had a large amount of marijuana in the apartment he shared with Segal on

Meaux Avenue in Lafayette and that Galetas and Richard should stay away from the

apartment. Galetas called Agent Jason Herpin of the Lafayette Metro Narcotics

Squad and reported the information about the marijuana. He allegedly told Herpin

that he did not want to be involved, because he had heard rumors that this was where

fellow police officer Trampus Gaspard was getting steroids. Herpin passed the

information on to Major Brian Baumgardner, Sergeant Gabriel Thompson, and

Corporal Kane Marceaux. Those officers, along with a K-9 officer, Corporal Brent

Taylor, went to the apartment to secure it while waiting for a search warrant. Cormier

was not at home when they arrived. While they were at the apartment, Richard called

Taylor saying that a friend had called and said that he had seen plain clothes police

officers at the apartment on Meaux Avenue. Richard allegedly asked Taylor what

was going on, and Taylor told him he should call Baumgardner. Richard then called

Baumgardner who told him that they were conducting a marijuana investigation at the

apartment. Cormier returned to the apartment, apparently having been at a nearby

1 apartment rented by his brother. Richard alleges that he was instrumental in

convincing Cormier to return to the apartment.

After obtaining a search warrant, the officers searched Cormier’s apartment and

found between twenty and twenty-five pounds of marijuana, a number of bottles of

steroids, and drug paraphernalia.

In the aftermath of the raid on the Meaux Avenue apartment, an investigation

was initiated by the Internal Affairs Division of the Lafayette Police Department (the

Department). Richard and Gaspard, among other officers, were subjected to

“reasonable suspicion” drug screening. Both tested positive for steroid use, and both

were terminated by the Chief of Police Randy Hundley (the Chief). After a hearing

on May 23, 2006, the Board affirmed Richard’s termination, but overturned

Gaspard’s termination. Richard appealed to the district court, which affirmed the

ruling of the Board. He now appeals that decision to this court. Finding that no

reasonable suspicion existed to test Richard, we reverse the ruling of the Board and

of the trial court.

DISCUSSION

Appeals of decisions of a civil service board are to be confined to “the

determination of whether the decision made by the board was made in good faith for

cause.” La.R.S. 33:2501(E)(3). The Louisiana Supreme Court in Moore v. Ware,

01-3341 (La. 2/25/03), 839 So.2d 940, 945-46, explained that:

If made in good faith and statutory cause, a decision of the civil service board cannot be disturbed on judicial review. Smith v. Municipal Fire & Police Civil Service Bd., 94-625 (La.App. 3 Cir. 11/02/94), 649 So.2d 566; McDonald v. City of Shreveport, 655 So.2d 588 (La.App. 2 Cir.1995). Good faith does not occur if the appointing authority acted arbitrarily or capriciously, or as the result of prejudice or political expediency. Martin v. City of St. Martinville, 321 So.2d 532 (La.App. 3 Cir.1975), writ denied, 325 So.2d 273 (La.1976). Arbitrary

2 or capricious means the lack of a rational basis for the action taken. Shields v. City of Shreveport, 579 So.2d 961, 964 (La.1991); Bicknell v. United States, 422 F.2d 1055 (5 Cir.1970). The district court should accord deference to a civil service board’s factual conclusions and must not overturn them unless they are manifestly erroneous. Shields v. City of Shreveport, 565 So.2d 473, 480 (La.App. 2 Cir.), aff’d, 579 So.2d 961 (La.1991). Likewise, the intermediate appellate court and our review of a civil service board’s findings of fact are limited. Shields, 579 So.2d at 964. Those findings are entitled to the same weight as findings of fact made by a trial court and are not to be overturned in the absence of manifest error. Id.; City of Kenner v. Wool, 433 So.2d 785, 788 (La.App. 5 Cir.1983).

It is undisputed that on June 15, 2006, the Chief ordered Richard to take a

“reasonable suspicion” drug screen. Richard asserts that there was no reasonable

suspicion as set out in the Lafayette Consolidated Government Policy and Procedure

Manual (PPM) 123–1§ 14. PPM 123–1 states that its purpose is to “eliminate

unauthorized drug use (including the unauthorized use of alcohol), drug users, drug

activities and drug effects from all work places.” To that end, Section 14 of PPM

123–1 provides for non-random drug tests as follows:

14.1 Testing on the basis of reasonable suspicion may be directed for reasons including, but not limited to, those identified below:

a. When a supervisor has reason to suspect that an employee is under the influence of drugs or alcohol due to the employees’s physical condition or unusual behavior while working, or other articulable reasons that would lead a prudent supervisor to be concerned about the individual’s safety or the safety of co-workers or the general public.

b. When a supervisor has reasonable suspicion of probable drug or alcohol abuse by an employee or a number of employees based on reliable information such as an unusual amount of accidents, incidents of theft, lost productivity or reports of unusual or unsafe behavior, or other facts that would justify testing specific individuals or groups due to safety concerns.

c. When a supervisor has a reasonable suspicion of possible drug or alcohol abuse based on an employee’s excessive

3 absenteeism or a suspicious pattern or trend of absenteeism.

d. When an employee is found in possession of suspected illicit or unauthorized drugs and/or alcohol, drug paraphernalia or when an such items are found in an area controlled or used exclusively or predominately by such employee.

e.

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Related

Samuel N. Bicknell v. United States
422 F.2d 1055 (Fifth Circuit, 1970)
Martin v. City of St. Martinville
321 So. 2d 532 (Louisiana Court of Appeal, 1976)
Smith v. EUNICE MUN. FIRE & POLICE BD.
649 So. 2d 566 (Louisiana Court of Appeal, 1994)
McDonald v. City of Shreveport
655 So. 2d 588 (Louisiana Court of Appeal, 1995)
Moore v. Ware
839 So. 2d 940 (Supreme Court of Louisiana, 2003)
Shields v. City of Shreveport
565 So. 2d 473 (Louisiana Court of Appeal, 1990)
City of Kenner v. Wool
433 So. 2d 785 (Louisiana Court of Appeal, 1983)
Shields v. City of Shreveport
579 So. 2d 961 (Supreme Court of Louisiana, 1991)
Banks v. Dept. of Public Safety & Corr.
598 So. 2d 515 (Louisiana Court of Appeal, 1992)
Safford v. Department of Fire
627 So. 2d 707 (Louisiana Court of Appeal, 1993)
Fraternal Order of Police, Lodge No. 5 v. Tucker
868 F.2d 74 (Third Circuit, 1989)

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John Keith Richard v. Lafayette Fire and Police Civil Service Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-keith-richard-v-lafayette-fire-and-police-civil-service-board-lactapp-2008.