Michael S. Peden v. City of Milwaukee Board of Fire and Police Commissioners

CourtCourt of Appeals of Wisconsin
DecidedMarch 5, 2024
Docket2022AP001086
StatusUnpublished

This text of Michael S. Peden v. City of Milwaukee Board of Fire and Police Commissioners (Michael S. Peden v. City of Milwaukee Board of Fire and Police Commissioners) is published on Counsel Stack Legal Research, covering Court of Appeals of Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael S. Peden v. City of Milwaukee Board of Fire and Police Commissioners, (Wis. Ct. App. 2024).

Opinion

COURT OF APPEALS DECISION NOTICE DATED AND FILED This opinion is subject to further editing. If published, the official version will appear in the bound volume of the Official Reports. March 5, 2024 A party may file with the Supreme Court a Samuel A. Christensen petition to review an adverse decision by the Clerk of Court of Appeals Court of Appeals. See WIS. STAT. § 808.10 and RULE 809.62.

Appeal No. 2022AP1086 Cir. Ct. No. 2020CV6800

STATE OF WISCONSIN IN COURT OF APPEALS DISTRICT I

MICHAEL S. PEDEN,

PETITIONER-APPELLANT,

V.

CITY OF MILWAUKEE BOARD OF FIRE AND POLICE COMMISSIONERS,

RESPONDENT-RESPONDENT.

APPEAL from an order of the circuit court for Milwaukee County: LAURA GRAMLING PEREZ, Judge. Affirmed.

Before White, C.J., Donald, P.J., and Geenen, J.

Per curiam opinions may not be cited in any court of this state as precedent

or authority, except for the limited purposes specified in WIS. STAT. RULE 809.23(3). No. 2022AP1086

¶1 PER CURIAM. Michael S. Peden appeals a circuit court order affirming a decision of the City of Milwaukee Board of Fire and Police Commissioners (“the Board”), which upheld the termination of Peden’s employment with the City of Milwaukee Fire Department (“MFD”). As discussed below, we reject Peden’s arguments and affirm.

BACKGROUND

¶2 On June 17, 2020, MFD Chief Mark Rohlfing terminated Peden from his position as a heavy-equipment operator. Rohlfing alleged that Peden had violated multiple rules and regulations stemming from an incident on June 5, 2020. In short, on that date, due to civil unrest, several fire stations were ordered to evacuate and relocate in order to keep personnel safe and remain available to respond to emergencies. Peden, who was on duty, was ordered to transfer to a different station. In response, Peden threatened to “lay up,” which is a reference to calling out sick, if he was made to transfer. Peden explained that he believed that Jason Strzelecki, who had allegedly framed him in a past sexual assault case,1 was scheduled to be working at the other station. Peden did not make any claim that he was actually ill or injured at that time. Due to his refusal to obey the order to transfer, Peden was sent home.

¶3 Peden appealed his termination to the Board, and an administrative hearing was scheduled for October 12, 2020. Prior to the hearing, Peden unsuccessfully sought to obtain materials relating to the sexual assault case and the

1 In 2017, Peden was charged with second-degree sexual assault of another firefighter, Aleah Ellis. Jason Strzelecki, also a firefighter and Ellis’s then-boyfriend, was interviewed in the investigation. In 2019, the criminal case was dismissed.

2 No. 2022AP1086

June 5, 2020 incident via open records requests. Subsequently, ten days before the hearing, Peden filed a Motion to Compel Discovery, which was denied.2 Then, one day before the hearing, Peden filed a Motion for Immediate Production of Exculpatory Evidence. The motion sought audio recordings of meetings relating to Peden’s termination, discipline, and charges, an activity log from June 5, 2020, member schedules, Strzelecki’s work assignment and changes on June 5, 2020, and records of “who ordered or directed the change [in the MFD’s computer assignment program] to ‘AWOL’ from ‘No pay – Failed to Work No Pay.’”

¶4 The administrative hearing took place as scheduled before a three- member panel. At the start of the hearing, the City of Milwaukee Attorney’s Office (“the City”) agreed to produce all of the materials requested in the Motion for Immediate Production of Exculpatory Evidence.3 Peden did not request an adjournment to obtain or review the materials.

¶5 The Board heard testimony from multiple witnesses, including Assistant Chief Aaron Lipski, Peden, Rebecca Coffee—Peden’s former defense attorney who represented him in the sexual assault case—and psychotherapist Jay Schrinsky, who opined that Peden suffers from posttraumatic stress disorder (PTSD) stemming from the sexual assault case. The Board unanimously concluded that Peden should be terminated.

2 According to the Board’s decision, the motion was denied because the Board found it had no authority to enforce a public records request and the statutes do not provide for discovery practice. 3 Later, the City noted that it was unable to fulfill Peden’s request for an audio recording of a disciplinary meeting as no such meeting took place.

3 No. 2022AP1086

¶6 Peden filed a statutory appeal pursuant to WIS. STAT. § 62.50 (2021- 22)4 and a petition for a writ of certiorari with the circuit court. After briefing and argument from the parties, the circuit court affirmed the Board. The circuit court found that Peden abandoned his request for certiorari review and that the record did not support a conclusion that the Board acted outside its jurisdiction or failed to proceed with a correct theory of law. In addition, the circuit court found that there was just cause for termination.

¶7 Peden now appeals the denial of his writ of certiorari. 5 Additional relevant facts are referenced below.

DISCUSSION

¶8 “When reviewing a petition for a writ of certiorari, we review the Board’s decision, not the decision of the circuit court.” Vidmar v. Milwaukee City Bd. of Fire Police Comm’rs, 2016 WI App 93, ¶13, 372 Wis. 2d 701, 889 N.W.2d 443. Our review is limited to whether the Board “kept within its jurisdiction and whether it proceeded on a correct theory of law.” Herek v. Police & Fire Comm’n of Menomonee Falls, 226 Wis. 2d 504, 510, 595 N.W.2d 113 (Ct. App. 1999). These are “questions of law we review de novo.” Vidmar, 372 Wis. 2d 701, ¶13.

4 All references to the Wisconsin Statutes are to the 2021-22 version unless otherwise noted. 5 The circuit court’s decision on Peden’s statutory appeal is not reviewable by an appellate court. Gentilli v. Board of Police & Fire Comm’rs, 2004 WI 60, ¶14, 272 Wis. 2d 1, 680 N.W.2d 335. When an order of the Board is sustained on a statutory appeal, the order is “final and conclusive.” Id.

4 No. 2022AP1086

¶9 On appeal, Peden does not challenge whether the Board kept within its jurisdiction. Rather, Peden contends that the Board failed to proceed on a correct theory of law.

¶10 To start, the parties address whether Peden abandoned his certiorari claims. Even if we assume that Peden did not abandon his certiorari claims, we conclude that Peden’s arguments fail on the merits.

¶11 Peden first argues that his right to due process was violated. Peden states that he “sought to obtain and present documents and other discoverable materials to assist in the presentation of his defense, including the difficulty he had been subjected to by the MFD in the criminal proceeding, and his resultant PTSD.” According to Peden, the Board prevented him from “obtaining the critical materials relating to the falsehoods perpetrated by existing MFD members and supervisors” and “blocked his efforts to provide the Board with the history of his battle to prevent a serious felony conviction[.]”

¶12 The Board responds that Peden’s due process rights were not violated because the materials he claims he needed were not relevant to the violations he faced. We agree.

¶13 “‘Relevant evidence’ means evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence.” WIS. STAT. § 904.01. “Evidence which is not relevant is not admissible.” WIS. STAT. § 904.02.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Pettit
492 N.W.2d 633 (Court of Appeals of Wisconsin, 1992)
Herek v. Police & Fire Commission of Menomonee Falls
595 N.W.2d 113 (Court of Appeals of Wisconsin, 1999)
Gentilli v. Board of the Police & Fire Commissioners
2004 WI 60 (Wisconsin Supreme Court, 2004)
Vidmar v. Milwaukee City Board of Fire Police Commissioners
2016 WI App 93 (Court of Appeals of Wisconsin, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Michael S. Peden v. City of Milwaukee Board of Fire and Police Commissioners, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-s-peden-v-city-of-milwaukee-board-of-fire-and-police-wisctapp-2024.