Miranda Pilato v. John Samaniego, Sheriff of Shelby County

CourtCourt of Civil Appeals of Alabama
DecidedJune 27, 2025
DocketCL-2024-0844
StatusPublished

This text of Miranda Pilato v. John Samaniego, Sheriff of Shelby County (Miranda Pilato v. John Samaniego, Sheriff of Shelby County) is published on Counsel Stack Legal Research, covering Court of Civil Appeals of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Miranda Pilato v. John Samaniego, Sheriff of Shelby County, (Ala. Ct. App. 2025).

Opinion

Rel: June 27, 2025

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter.

ALABAMA COURT OF CIVIL APPEALS OCTOBER TERM, 2024-2025 _________________________

CL-2024-0844 _________________________

Miranda Pilato

v.

John Samaniego, Sheriff of Shelby County

Appeal from Shelby Circuit Court (CV-22-380)

PER CURIAM.

Miranda Pilato appeals from a judgment entered by the Shelby

Circuit Court ("the circuit court") affirming a decision of the Shelby

County Law Enforcement Personnel Board ("the LEPB") that affirmed

the termination by John Samaniego, the Sheriff of Shelby County, of CL-2024-0844

Pilato's employment as a Shelby County deputy sheriff. We affirm the

circuit court's judgment.

Background

Miranda Pilato began her employment with the Shelby County

Sheriff's Office ("the SCSO") on April 23, 2018. On June 2, 2022, Pilato

was informed by Sheriff Samaniego that the SCSO had initiated an

administrative investigation regarding her job performance and that,

pending the results of that investigation, Pilato would be temporarily

assigned to desk duty. On June 6, 2022, Pilato was provided written

notice that the SCSO had initiated an administrative investigation

regarding her job performance and informing Pilato of her rights and

responsibilities related to that investigation. On June 8, 2022, several

members of the SCSO met with Pilato to discuss her job performance

regarding events that occurred on January 3, 2022, May 3, 2022, and May

28, 2022. At the conclusion of that meeting, Pilato was informed that she

could either resign her employment or that her employment would be

terminated. Pilato refused to resign and, thus, Sheriff Samaniego

terminated her employment. Pilato filed a notice of appeal requesting a

hearing before the LEPB regarding the termination of her employment.

2 CL-2024-0844

On July 26, 2022, the LEPB conducted an evidentiary hearing. At

that hearing, Pilato denied that her actions in the three events had

violated the SCSO Policies and Procedures. Additionally, Pilato argued

that she had been denied due process because she had not been provided

a pretermination hearing and had not received 10-days' advance notice

of the charges against her before her employment was terminated. On

July 28, 2022, counsel for the LEPB notified Pilato and Sheriff

Samaniego that it had affirmed Sheriff Samaniego's termination of

Pilato's employment. On July 30, 2022, Pilato's counsel requested a

rehearing of the LEPB's decision.

On August 16, 2022, the LEPB entered an order that, among other

things, scheduled a rehearing to occur on September 20, 2022, and

instructed counsel for both parties to submit a written brief outlining

their respective arguments, positions, and supporting authority. On

September 13, 2022, Pilato's counsel filed a brief in support of rehearing

in which he argued that the evidence regarding the January 3, 2022,

incident had been insufficient; that Pilato's actions on May 3, 2022, and

May 28, 2022, had been lawful and had not violated the SCSO Policies

and Procedures; that the due-process rights to which Pilato was entitled

3 CL-2024-0844

under Cleveland Board of Education v. Loudermill, 470 U.S. 532, 546

(1985), and Todd v. Kelly, 783 So. 2d 31 (Ala. Civ. App. 2000), were

violated when she was not afforded a pretermination hearing; that the

termination of Pilato's employment violated her due-process rights under

the SCSO Policies and Procedures because she was not provided written

notice of the charges against her in advance of the termination of her

employment; and that the decision of the LEPB to uphold the termination

of Pilato's employment had not been made by an unbiased decisionmaker.

On September 20, 2022, the LEPB conducted a rehearing. Pilato's

counsel and counsel for the SCSO made arguments, but no witnesses

were called or examined. Pilato's counsel generally reasserted the

arguments that he had made in his brief in support of rehearing. The

SCSO's counsel countered that, as an elected official, Sheriff Samaniego

and his deputies, which are alter egos of the sheriff, are exempted from

the protections of the Alabama Merit System Act, Ala. Code 1975, § 36-

26-1 et seq., which require a pretermination hearing. Thus, SCSO's

counsel asserted that Pilato's reliance on Loudermill and Kelly, neither

of which involved the termination of the employment of a county sheriff's

deputy, was misplaced. On September 23, 2022, counsel for the LEPB

4 CL-2024-0844

again notified Pilato and Sheriff Samaniego that the LEPB had affirmed

the decision of Sheriff Samaniego terminating Pilato's employment.

On September 28, 2022, Pilato filed an appeal in the circuit court,

challenging the termination of her employment by Sheriff Samaniego

and the decision of the LEPB upholding that termination. On October 7,

2024, the circuit court entered an "Order on Appeal" affirming the

LEPB's decision upholding the termination of Pilato's employment.

Pilato did not seek postjudgment relief. On October 23, 2024, Pilato filed

a notice of appeal to this court.

Issues

On appeal to this court, Pilato first argues that the circuit court's

judgment affirming the termination of her employment is due to be

reversed because, she says, her rights to due process under the United

States Constitution were violated when she was not afforded a

pretermination hearing. She also contends that the termination of her

employment violated her due-process rights under the SCSO Policies and

Procedures because she was not provided written notice of the charges

against her in advance of the termination of her employment and that

the decision to terminate her employment was not made by an unbiased

5 CL-2024-0844

decisionmaker. Finally, she argues that the facts do not support the

termination of her employment.

Standard of Review

"Judicial review of administrative decisions like those of the LEPB [Law Enforcement Personnel Board] is generally governed by the enabling act that created the particular administrative body or by the regulations governing the particular administrative body. See, generally, Ex parte Smith, 394 So. 2d 45, 48 (Ala. Civ. App. 1981). Typically, the standard of review of administrative decisions requires that the circuit court uphold the administrative decision if it is supported by substantial and legal evidence. Ex parte Personnel Bd. of Jefferson County, 648 So. 2d 593, 594 (Ala. Civ. App. 1994), Board of Water & Sewer Comm'rs [of Mobile v. Smith], 591 So. 2d [521,] 522 [(Ala. Civ. App.

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Related

Cleveland Board of Education v. Loudermill
470 U.S. 532 (Supreme Court, 1985)
Colonial Mgmt. Group v. State Health Planning and Dev. Agency
853 So. 2d 972 (Court of Civil Appeals of Alabama, 2002)
Stallworth v. City of Evergreen
680 So. 2d 229 (Supreme Court of Alabama, 1996)
Alabama Renal Stone Inst v. A.S.H.C.C.
628 So. 2d 821 (Court of Civil Appeals of Alabama, 1993)
City of Mobile v. Personnel Board for Mobile County
329 So. 2d 570 (Court of Civil Appeals of Alabama, 1976)
Ex Parte Boyette
728 So. 2d 644 (Supreme Court of Alabama, 1998)
Todd v. Kelley
783 So. 2d 31 (Court of Civil Appeals of Alabama, 2000)
Sylacauga Health Care Center, Inc. v. Alabama State Health Planning Agency
662 So. 2d 265 (Court of Civil Appeals of Alabama, 1994)
Ex Parte Smith
394 So. 2d 45 (Court of Civil Appeals of Alabama, 1981)
Ex Parte Personnel Bd. of Jefferson County
648 So. 2d 593 (Court of Civil Appeals of Alabama, 1994)
Health Care Auth. of City of Huntsville v. State Health Plan. Agency
549 So. 2d 973 (Court of Civil Appeals of Alabama, 1989)
Blount County Commission v. Clinton A. Sherrell.
77 So. 3d 1196 (Court of Civil Appeals of Alabama, 2010)
Lawson v. Shelby County Sheriff's Office
961 So. 2d 158 (Court of Civil Appeals of Alabama, 2007)

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Miranda Pilato v. John Samaniego, Sheriff of Shelby County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miranda-pilato-v-john-samaniego-sheriff-of-shelby-county-alacivapp-2025.