Kline v. Hampton Township

42 Pa. D. & C.2d 49, 1967 Pa. Dist. & Cnty. Dec. LEXIS 178
CourtPennsylvania Court of Common Pleas, Alleghany County
DecidedJanuary 5, 1967
Docketno. 834
StatusPublished
Cited by3 cases

This text of 42 Pa. D. & C.2d 49 (Kline v. Hampton Township) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Alleghany County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kline v. Hampton Township, 42 Pa. D. & C.2d 49, 1967 Pa. Dist. & Cnty. Dec. LEXIS 178 (Pa. Super. Ct. 1967).

Opinion

Brown, J.,

This case arises out of the promotion and demotion of a police officer of Hampton Township, a township of the second class situated in the County of Allegheny, Pa., and his subsequent petition for appeal under the Police Tenure [50]*50Act of June 15, 1951, P. L. 586, as amended, 53 PS §812.

Petitioner here, Officer Chester J. Kline, had served on the Hampton Township Police Force for approximately five years prior to the beginning of January, 1965, in the capacity of patrolman. Starting about the first day of January, 1965, Officer Kline assumed the duties of a lieutenant on the force. On March 1, 1965, the Board of Supervisors of Hampton Township moved to appoint Officer Kline a lieutenant at the executive meeting of March 1, and made that appointment retroactive to January 1, granting back pay to that date. The minutes of the executive meeting of March 1 contained the following notations under item 14: “Appointment of Lt. Hamilton moved, Mair seconded, ET no, F.H. yes, C.K. yes”. This notation refers to the action of the executive board in appointing Officer Kline to lieutenant. The motion was made by Hamilton, seconded by Supervisor Mair, and the vote was, E. W. Tappe, “no”; C. M. Knox, “yes”, and Francis Hamilton, “yes”. From the testimony, it is clear that it was the practice and the custom of the township board of supervisors to discuss and conduct much business at the executive meetings which were held on the first Tuesday of each month. The minutes of the executive meetings were read at the public meetings, and, according to the testimony, actions taken at the meetings were generally assumed to be approved upon the reading of the minutes at the public meeting. This court realizes that it is the law that the mere reading of the executive meeting minutes at a public meeting, without more, does not constitute a ratification or adoption of the actions taken at the executive meeting. However, in this case there was more. At the public meeting of March 16, 1965, the promotion of Lieutenant Kline was vigorously discussed and the position of the members of the board was clearly stated, and [51]*51the testimony reveals that their actions on this matter did constitute an adoption or ratification of their prior action, as we will discuss later. The original minutes of the public meeting of March 16, 1965, have been lost. Officer Kline has been deprived of these notes, which might have been very helpful to his case, through no fault of his own. The court has noted the unbusinesslike manner in which the shorthand notes were transcribed; the fact that the original meeting notes were lost; and the fact that the township supervisor condensed the notes before they were read at the subsequent meeting.

Officer Kline served as lieutenant until March 21, 1966. He was then notified by the township manager and the police chief that effective March 22, he was no longer to continue as a lieutenant, but was to resume the duties of patrolman. He then made a demand for written charges and subsequently, by his attorney, made another demand for charges and for a hearing— all of which were ignored. Kline now appeals under the Police Tenure Act of 1961, supra.

The township strongly relies on Templeton Appeal, 399 Pa. 10 (1960), for the proposition that a void appointment confers upon the appointed officer no status in the appointive position. Templeton is inapposite, for there the borough attempted to appoint a chief of police, although it had never created a police force as required by the borough code.

If Officer Kline’s appointment is void, then he is entitled to no protection under the Police Tenure Act of 1951, as amended, supra, which is as follows:

“Section 2. Removals. — No person employed as a regular full time police officer in any police department of any township of the second class . . . with the exception of policemen appointed for a probationary period of one year or less, shall be suspended, removed or reduced in rank except for the following [52]*52reasons: (1) physical or mental disability affecting his ability to continue in service, in which case the person shall receive an honorable discharge from service; (2) neglect or violation of any official duty; (3) violating of any law which provides that such violation constitutes a misdemeanor or felony; (4) inefficiency, neglect, intemperance, disobedience of orders, or conduct unbecoming an officer; (5) intoxication while on duty. A person so employed shall not be removed for religious, racial or political reasons. A written statement of any charges made against any person so employed shall be furnished to such person within five days after the same are filed”.

However, this court must first determine whether Officer Kline’s appointment was in fact void, as claimed by the township.

In order to make this determination, we must first determine: (a) whether the promotion of a police officer in a second class township need be done at a public meeting; and if so, (b) whether there was action by the township board of supervisors promoting Officer Kline at a public meeting.

The township solicitor, in his brief, at page 2 states:

“It is the contention of the Township that an executive session is not a duly constituted or legal meeting of the Board of Supervisors and as a result no business can be transacted relating to Township affairs”.

This is not an accurate statement of the law in Pennsylvania. The township has cited no authority for the proposition; nor has the court been able to discover any. It is true that the Act of June 21, 1957, P. L. 392, sec. 1(B), 65 PS §251 et seq., requires, as we shall discuss subsequently, that the promotion of a police officer be done at a public meeting. This section does not state, however, that an executive session is not a duly constituted or legal meeting; nor does it state that no township business may be conducted at [53]*53such a meeting. The Act of 1957, supra, provides, inter alia, as follows:

“(B) Public Meeting. That part of any meeting of a board during which it votes upon any ordinance, resolution, motion or other official action proposed by or to the board dealing with the receipt, borrowing or disbursement of funds or the acquisition, use or disposal of services or of any supplies, materials, equipment or other property or the fixing of personal or property rights, privileges, immunities, duties or obligations of any person or group of persons: Provided, That the term ‘Public Meeting’ shall not mean any meeting, the publication of the facts concerning which would disclose the institution, progress or result of an investigation undertaken by a board in the performance of its official duties”.

This statute is applicable to any meeting which deals with the “disposal of services”. The action of a township board of supervisors in promoting a police officer is an action which disposes of services, to wit, the services of the police officer. Likewise, it should be noted that the statute applies to actions of a board resulting in the “disbursement of funds”. Here again, there is no question that the promotion of a police officer will require the disbursement of additional funds in the form of a monthly increase in wages paid to the officer. This clearly appears from the testimony, and neither party contends otherwise.

Lastly, the statute applies to board actions which fix “personal or property rights, privileges, immunities, duties or obligations of any person. . .

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Cite This Page — Counsel Stack

Bluebook (online)
42 Pa. D. & C.2d 49, 1967 Pa. Dist. & Cnty. Dec. LEXIS 178, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kline-v-hampton-township-pactcomplallegh-1967.