New Haven Police Local 530 v. Logue

449 A.2d 990, 188 Conn. 290, 1982 Conn. LEXIS 595
CourtSupreme Court of Connecticut
DecidedSeptember 7, 1982
StatusPublished
Cited by7 cases

This text of 449 A.2d 990 (New Haven Police Local 530 v. Logue) is published on Counsel Stack Legal Research, covering Supreme Court of Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
New Haven Police Local 530 v. Logue, 449 A.2d 990, 188 Conn. 290, 1982 Conn. LEXIS 595 (Colo. 1982).

Opinion

Parskey, J.

The defendants appeal from a declaratory judgment rendered by the trial court which held void appointments of the defendant police officers to posts created by a reorganization of the New Haven police department effective May 1, 1978. The plaintiffs, Thomas Muller and Leonard Gallo, 1 hold the ranks of lieutenant and sergeant, respectively, in the department. The defendants are police officers appointed to posts under the reorganization plan, the chief of police, mayor, and the city officials responsible for filling and financing the jobs in question. The plaintiffs challenged the authority of the police chief to make the subject appointments without first holding competitive examinations.

The defendant officers held the ranks of captain, lieutenant, or sergeant before the reorganization. The plan eliminated the titles of deputy chief and assistant chief in the organizational hierarchy, created the titles of director, chief duty commander, duty commander, and unit commander, and rearranged the placement of various police functions under the new hierarchy. After May 1, 1978, the chief vested the defendant officers with the new titles 2 pursuant to the discretionary authority *292 granted solely to Mm by virtue of section 111 of the New Haven City Charter. 3 At the same time, pursuant to section 104 of the charter, 4 the chief and the board of police commissioners enacted a rule requiring approval by the board of these and other such appointments in the future. The board of police commissioners approved the subject appointments on April 30, 1978. Because these appointments were made without first holding competitive examinations as required by section 198 of the charter 5 and rule VI, section 2, of the civil *293 service rnles and regulations, 6 the trial court nullified them, 7 ordered the civil service "board to hold examinations, and ordered the relevant officials to comply with the applicable rules in filling the positions. 8

*294 On appeal, the defendants claim: (1) that the plaintiffs lack standing to maintain the action; (2) that the court erred in finding a charter requirement of merit selection rather than a license for discretionary designation to the subject posts; (3) that the court erred in concluding that the parties conceded that the subject posts were in the classified service; and (4) that the court erred in substituting its judgment for the judgment of the police chief and responsible city agencies. For the reasons set forth below, we affirm the decision of the trial court.

I

Standing

The defendants contend that the plaintiffs, a lieutenant and a sergeant, lack standing in this case because only captains are eligible to compete for appointments to slots created by the reorganization since the posts are functionally superior to the rank of captain under the plaintiffs’ theory of the case. *295 “"While the declaratory judgment procedure may not be utilized merely to secure advice on the law ... or to establish abstract principles of law ... or to secure the construction of a statute if the effect of that construction will not affect a plaintiff’s personal rights ... it may be employed in a justiciable controversy where the interests are adverse, where there is an actual bona fide and substantial question or issue in dispute or substantial uncertainty of legal relations which requires settlement, and where all persons having an interest in the subject matter of the complaint are parties to the action or have reasonable notice thereof.” (Citations omitted.) Horton v. Meskill, 172 Conn. 615, 627, 376 A.2d 359 (1977); see also General Statutes § 52-29; Practice Book §§ 388-394.

The issue raised in this case is the standard of eligibility for appointment to posts characterized by the plaintiffs as positions which require merit selection and by the defendants as duty assignments which are discretionary designations. The designated titles do not correspond uniquely to a rank. Sergeants, lieutenants, and captains all occupy the posts of director or commander. 9 Nine of the defendants equal in rank to the plaintiffs achieved these offices. The plaintiffs’ request for declaratory judgment requires an inquiry into the relevant authority by which such appointments may be made. It is unclear whether, if an equivalency between title and rank were drawn, in fact only captains would be eligible to compete for each title. It is clear that many sergeants and lieutenants were excluded from consideration and the few who were called were chosen. The uncertainty of the plain *296 tiffs’ rights under this system confers upon them standing under Practice Book § 390 10 to challenge the practice.

n

Charter Authority

The focus of debate in this case is whether the new posts of the defendant officers constitute appointments or promotions to positions and hence are governed by section 198 of the city charter, or whether they are merely assignments to duty and hence are governed by section 111 of the charter. If the posts are duty assignments as the defendants contend, the chief may designate officers to such duties at his discretion without regard to civil service merit selection regulations. New Haven Charter & 111 (1977). If, however, the posts are positions as the plaintiffs contend, they must be filled according to civil service rules.

*297 To determine the intent of the charter, “[t]he enactment must be examined in its entirety and its parts reconciled and made operative so far as possible.” McAdams v. Barbieri, 143 Conn. 405, 418, 123 A.2d 182 (1956). “Duty assignment” is nowhere defined in the charter or civil service rules and regulations. “Position” is definition number 17 of the civil service rules and regulations: “A group of duties and responsibilities requiring the full-time employment of one person.” New Haven Civil Service Commission Rules and Regulations, p. 6; see General Statutes § 5-196 (u); State v. Griswold, 73 Conn. 95, 97, 46 A. 829 (1900). It logically follows from the definition of “position” that an assignment to duty constitutes an order to perform a particular task encompassed in the scope of the employee’s position. 11

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

Related

Austin v. Bridgeport
D. Connecticut, 2019
Fitzgerald v. City of Bridgeport
202 A.3d 385 (Connecticut Appellate Court, 2019)
Kelly v. City of New Haven
881 A.2d 978 (Supreme Court of Connecticut, 2005)
Meyer v. Collins
717 A.2d 771 (Connecticut Appellate Court, 1998)
Stamford Ridgeway Associates v. Board of Representatives
572 A.2d 951 (Supreme Court of Connecticut, 1990)
Civil Service Commission v. Pekrul
571 A.2d 715 (Connecticut Superior Court, 1989)
Kenny v. Civil Service Commission
496 A.2d 956 (Supreme Court of Connecticut, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
449 A.2d 990, 188 Conn. 290, 1982 Conn. LEXIS 595, Counsel Stack Legal Research, https://law.counselstack.com/opinion/new-haven-police-local-530-v-logue-conn-1982.