Murphy v. Bd. of Commissioners of Lower Merion Twp.

40 Pa. D. & C.3d 577, 1985 Pa. Dist. & Cnty. Dec. LEXIS 117
CourtPennsylvania Court of Common Pleas, Montgomery County
DecidedSeptember 13, 1985
Docketno. 84-01549
StatusPublished

This text of 40 Pa. D. & C.3d 577 (Murphy v. Bd. of Commissioners of Lower Merion Twp.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Montgomery County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Murphy v. Bd. of Commissioners of Lower Merion Twp., 40 Pa. D. & C.3d 577, 1985 Pa. Dist. & Cnty. Dec. LEXIS 117 (Pa. Super. Ct. 1985).

Opinion

BRODY, J.,

This opinion is necessitated by petitioner’s appeal of this court’s order of June 12, 1985, which dismissed his appeal from the decision of the Civil Service Commission of Lower Merion Township dated December 29, 1983.

BACKGROUND

Petitioner Raymond Murphy has been employed by Lower Merion Township as a police officer for 22 years; in 1967, he attained the rank of sergeant. On January 18, 1980, petitioner was working as patrol sergeant on the 8:00 p.m. to midnight shift. At approximately 10:50 p.m., petitioner was dispatched to the scene of a disruptive party, along with two other officers. Upon arriving, they discovered more than 50 young people, a keg of beer and beer cans strewn throughout the house. Petitioner consulted with the property owners’ daughter and then directed that the keg be emptied. Petitioner took no other official action at that time or later; he never contacted the owner of the premises nor attempted to ascertain names of those at the party or whether those leaving were, in fact, too intoxicated to drive:

Upon returning to his patrol car, a marked police unit, petitioner discovered that a camera, a mace kit and a raincoat had been stolen from it. Petitioner’s initial report of the incident to his supervisor- indicated that he had secured his vehicle prior to entering the residence despite the fact that while in the residence he had been informed by another officer that his passenger-side window was open. A supple[579]*579mental report filed by petitioner, however, indicated that petitioner may have left this window partially rolled down. The teenager subsequently charged with theft of the items taken stated that he had gained entry to the car by way of an open window.

On February 13, 1980, the Superintendent of Police of Lower Merion Township filed a statement charging petitioner with dereliction of duty, failure to report under-age drinking, failure to secure his police Vehicle and hindering the investigation of the theft from his vehicle. The superintendent’s disposition of the case was to permanently reduce petitioner’s rank from that of sergeant to that of Grade “A” patrolman with a proportional reduction in salary, effective February 21, 1980.

On February 19, 1980,. petitioner requested a hearing before the township’s Civil Service Commission pursuant to the First Class Township Code, 53 P.S. §55645. Petitioner then filed a complaint in equity seeking to enjoin the Civil Service Commission from holding a hearing based on various procedural irregularities. The township’s preliminary objections to this complaint were sustained by this court (Lowe, P.J.) on the basis that petitioner had failed to exhaust his statutory remedies pursuant to the First Class Township Code, 53 P.S. §55645. This order was affirmed by the Commonwealth Court of Pennsylvania on April 11, 1983, Murphy v. Township of Lower Merion, 73 Pa. Commw. 376, 457 A.2d 1342 (1983).

The Civil Service Commission of Lower Merion Township then held a hearing on July 19, 1983. By letter of December 29, 1983, petitioner was notified that the commission had, by a two-to-one vote, affirmed the police superintendent’s decision to demote Sergeant Murphy to Grade “A” patrolman.

[580]*580Petitioner then appealed the commission’s decision to this court. After oral argument, an order was entered dismissing petitioner’s appeal. It is from this order that petitioner now appeals.

DISCUSSION

A. Standard of Review

The First Class Township Code, 53 P.S. §55645, Act of June 3, 1971, P.L. 133, provides that a police officer reduced in rank can demand a hearing before the Civil Service Commission and that, in the event the commission sustains the reduction, the officer can appeal to the court of common pleas. “[T]he case shall there be determined as the court deems proper.”

In making this determination, a court of common pleas is guided by the principle that: “The decision rendered by a civil service commission must be upheld unless there has been a violation of constitutional rights, an error of law, noncompliance with the Local Agency Law or if any factual finding made by the commission necessary to support its decision is not supported by substantial evidence.” Schmidt v. Borough of Baldwin, 82 Pa. Commw. 580, 583, 477 A.2d 572, 574 (1984).

We also note that: “It is necessary that both court and commission give due respect and weight to the action of the duly constituted municipal body which is authorized to act with respect to charges against members of the police force.” Appeal of Zimmett, 28 Pa. Commw. 103, 107, 367 A.2d 382, 384 (1977). Decisions as to discipline of police officers are properly left to the appropriate municipal authority. In making its determination, this court will not usurp this power, but rather will examine the adjudication of the Civil Service Commission to ensure that its [581]*581decision is supported by sufficient evidence and reflects no abuse of discretion or error of law.

B. Petitioner’s Allegations

Petitioner alleges that this court was erroneous in upholding the decision of the Civil Service Commission. Initially, petitioner claims that the statutorily required notice of charges against him filed on behalf of the township was insufficient to fully advise petitioner of all the charges pending and that this deficiency amounted to a denial of due process of law.

An examination of the specifications and charges filed by James J. McCaughey, superintendent of police, on February 13, 1980, shows this to be untrue. The superintendent’s itemization of specifications and charges is thorough, complete and fully discusses both the facts and the resulting charges in this case. The notice of charges against petitioner was more than adequate, see Danner v. Bristol Township Civil Service Commission, 64 Pa. Commw. 470, 440 A.2d 702 (1982), and there was no denial of due process in this, regard.

Petitioner next complains that his counsel was given inadequate time to review subpoenaed documents prior to the hearing, amounting to a nullificiation of the subpoena power found in the First Class Township Code, 53 P.S. §55633, and therefore resulting in a denial of due process of the law.

Section 55633 of the First Class Township Code states that:

“The commission shall have the power to issue subpoenas over the signature of the chair (person) to require the attendance of witnesses and the production of records and papers pertaining to any investigation or inquiry.”

[582]*582This section is included in that portion of the code discussing the formation, responsibilities, and powers of the Civil Service Commission. The provision cited grants the commission power to subpoena documents for its own review in the course of an investigation; it does not purport to give a civil servant broad powers of discovery in these cases. Additionally, the record reflects that the hearing was interrupted for a 20-minute period in order to permit petitioner’s counsel to familiarize himself with the subpoenaed documents.

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455 A.2d 1297 (Commonwealth Court of Pennsylvania, 1983)
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Bluebook (online)
40 Pa. D. & C.3d 577, 1985 Pa. Dist. & Cnty. Dec. LEXIS 117, Counsel Stack Legal Research, https://law.counselstack.com/opinion/murphy-v-bd-of-commissioners-of-lower-merion-twp-pactcomplmontgo-1985.