Jonathan Hardin v. louisville/jefferson County Metropolitan Government

CourtCourt of Appeals of Kentucky
DecidedFebruary 10, 2022
Docket2021 CA 000234
StatusUnknown

This text of Jonathan Hardin v. louisville/jefferson County Metropolitan Government (Jonathan Hardin v. louisville/jefferson County Metropolitan Government) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jonathan Hardin v. louisville/jefferson County Metropolitan Government, (Ky. Ct. App. 2022).

Opinion

RENDERED: FEBRUARY 11, 2022, 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2021-CA-0234-MR

JONATHAN HARDIN APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE MARY M. SHAW, JUDGE ACTION NO. 19-CI-000858

LOUISVILLE/JEFFERSON COUNTY METROPOLITAN GOVERNMENT AND LOUISVILLE METRO POLICE MERIT BOARD APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, CETRULO, AND JONES, JUDGES.

CALDWELL, JUDGE: Jonathan Hardin (“Hardin”) appeals the decision of the

Jefferson Circuit Court upholding the Louisville Metro Police Merit Board (“Merit

Board”) action of approving the termination of his employment as a police officer

by the chief of police, Steve Conrad (“Chief Conrad”). Chief Conrad had terminated Hardin after allegations of Hardin’s

failure to follow proper police procedures were investigated and substantiated to

the Chief Conrad’s satisfaction. Hardin appealed his termination to the Merit

Board. The Merit Board held a four-day hearing into the termination decision and

upheld the decision to terminate Hardin.

Hardin appealed his termination to the Jefferson Circuit Court for

administrative review pursuant to Kentucky Revised Statute (“KRS”)

67C.323(3)(a).1 In the circuit court, Hardin alleged that since related criminal

records were ultimately expunged, the Merit Board erred when it did not grant his

motion that all materials contained in the criminal case file not be admitted at the

hearing. He also argued he was denied the right to confront witnesses at the

hearing when their transcribed testimony from the investigation of the allegations

was presented rather than live testimony.

1 KRS 67C.323(3)(a) states:

Every action of a dismissal, suspension, or demotion made by the board shall be final, except that any person aggrieved may, within thirty (30) days after the action, appeal to the Circuit Court of the county in which the board meets. The board shall be named respondent as the consolidated local government police force merit board, and service shall be had on the chairman of the board. Notice of the appeal shall be given to the chief or the officer if not already a party to the appeal as real parties in interest. The appeal taken to the Circuit Court shall be docketed by the clerk as a civil action with appropriate judicial review of an administrative action or decision.

-2- The circuit court affirmed the Merit Board. After reviewing the

record, the circuit court decision, and the briefs of the parties, we affirm the circuit

court.

FACTS

In 2015, Appellant Jonathan Hardin was a Louisville Metro Police

Officer assigned as a student resource officer at Olmstead Academy North, a

public middle school in Jefferson County. He had been an officer for six years at

the time of this assignment.

On January 22, 2015, Hardin was in the cafeteria during the lunch

period speaking with a school employee when a student attempted to cut the lunch

line. The school employee directed the student to the back of the line, but the

student ignored the employee’s direction. Hardin then intervened and repeated the

employee’s instruction that the student go to the back of the line. In response, the

thirteen-year-old student balled his hands into fists and refused to move. Hardin

pushed the student and then punched him in the face, with a closed fist. Hardin

then pinned the student on the ground and threatened to utilize his taser on the

student if the student continued to resist. The student relented, was handcuffed,

and was transported to the hospital for treatment of injuries he sustained. After

treatment, the student was released to his parent and was criminally charged with

menacing and resisting arrest.

-3- Several days later, on January 27, 2015, Hardin was in a hallway of

the school when a student took a step towards him and mimed shooting a

basketball over Hardin’s head. Another student simultaneously pushed Hardin,

and while Hardin was admonishing the second student, a third student pushed

Hardin very hard, causing him to fall to the floor. Hardin got up from the floor and

approached the third student from the back, grabbing him around the chest and

lifting him off the floor. Hardin held the student in the air for approximately

twelve seconds while the student tapped Hardin’s arms and swung his feet, fighting

for air before going limp. Hardin then lowered the student and laid him on the

floor. The student regained consciousness soon thereafter and was handcuffed by

Hardin for a short time.

Instead of charging the student with a criminal offense, Hardin took

the student outside to exercise and then took him into the auditorium to play piano

for the student, hoping to calm him. Finally, Hardin drove the child home to his

parent after the principal approved him doing so.

Both incidents were captured on video tape. The January 22 incident

was reported by Hardin to his supervising officer in accordance with standard

police policy. His supervisor completed an administrative incident report,

necessary any time an officer or an arrestee is injured during an arrest. The

January 27 incident was not reported by Hardin to his superior officer, but rather to

-4- the student resource officer commander. Hardin told the commander it was not

necessary to file an administrative incident report because no injuries occurred.

However, after viewing the video of the January 27 incident, the commander chose

to report it, which report resulted in an investigation of the incident.

After internal reviews of both incidents, Hardin was criminally

charged on February 3, 2015, with assault in the fourthdegree, official misconduct

in the first degree, and false swearing in relation to the January 22 incident. The

charges were eventually dismissed and were the subject of an expungement order

issued on January 19, 2016.

In relation to the January 27 incident, Hardin was charged with

official misconduct in the first degree (eventually amended to official misconduct

in the second degree), assault in the first degree (eventually amended to assault in

the fourth degree), and wanton endangerment. He was tried by a jury in June of

2018, and was found not guilty of the amended charges.

Hardin also faced disciplinary action after the internal investigations

of both incidents were completed. On March 20, 2015, Chief Conrad terminated

Hardin for violations of Louisville Metro Police Department (“LMPD”) Standard

Operating Procedures (“SOP”). Chief Conrad articulated in the letter of

termination that he found that Hardin had violated SOP 9.1.4, Use of Physical

Force, in both instances; SOP 10.7.2, Taking Juveniles into Custody, for the

-5- January 22 incident; and SOP 5.1.2, Obedience to Rules and Regulations, for the

criminal charges brought against Hardin flowing from both incidents.

Hardin appealed his termination by Chief Conrad to the Merit Board.

The Merit Board is vested with authority to review personnel decisions concerning

sworn officers by KRS 67C.323. Hardin requested that the Merit Board hearing be

delayed until after the criminal proceedings were completed, which was granted.

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