Nichols v. City of Jackson

848 F. Supp. 718, 1994 U.S. Dist. LEXIS 4977, 1994 WL 131094
CourtDistrict Court, S.D. Mississippi
DecidedMarch 31, 1994
Docket3:92-cv-00532
StatusPublished
Cited by12 cases

This text of 848 F. Supp. 718 (Nichols v. City of Jackson) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nichols v. City of Jackson, 848 F. Supp. 718, 1994 U.S. Dist. LEXIS 4977, 1994 WL 131094 (S.D. Miss. 1994).

Opinion

MEMORANDUM OPINION AND ORDER

TOM S. LEE, District Judge.

This cause is before the court on the motion of defendants City of Jackson (City), Joseph L. Donovan and Joseph N. Graham for summary judgment pursuant to Rule 56 of the Federal Rules of Civil Procedure. Plaintiff Larry Nichols filed a response and, having considered the memorandum of both parties as well as other relevant authorities, the court concludes that defendants’ motion should be granted in part and denied in part.

Plaintiff, a former City fireman, brings this federal question suit pursuant to 42 U.S.C. § 1983, and alleges that defendants suspended him in violation of his constitutional rights. 1 Specifically, he alleges that they discriminated against him on the basis of his race in violation of the Equal Protection and Due Process Clauses of the Fourteenth Amendment, violated his First Amendment rights and denied him constitutional due process. He also claims that his suspension was part of the fire department’s plan to replace firemen, ages forty to seventy — which included Nichols, a fifty-year-old — with younger men, which he claims violated the Age Discrimination in Employment Act, 29 U.S.C. § 621 et seq.

Background

On or about June 17, 1992, plaintiff, a twenty-year employee of and captain in the Jackson Fire Department, allegedly was involved in an altercation with a fellow fireman, Captain Hayman. Apparently, this dispute arose over the ownership of an extension cord. Nichols’ deposition testimony indicates he became angry when Hayman failed to listen to his explanation as to the ownership of the cord. The dispute escalated into violence when Nichols, the aggressor in this altercation, grabbed Hayman by the head and began to shake it.

Donovan, in his capacity as the City’s fire chief, received notification of this incident and directed Graham, the assistant fire chief, to conduct an investigation into the incident and provide a recommendation of punishment. On June 29, 1992, after completing his investigation, Graham recommended that plaintiff be suspended for sixty days without pay. Donovan approved the recommendation the same day. The official reason cited by Donovan for plaintiffs suspension was violation of Civil Service Rule XII, sec. 2.1.1., parts F and M — offensive conduct or language toward a fellow officer and conduct unbecoming to a city employee. This suspension was to begin on July 1, 1992; Nichols resigned on June 30,1992, one day before the suspension took effect. He filed this suit shortly thereafter, alleging numerous claims against defendants, which the court will now address.

Analysis

1. Procedural Due Process

The Fourteenth Amendment forbids states from depriving an individual of life, liberty or property without due process. Evaluation of a procedural due process claim is a two-step process. The first step requires the court to decide whether a protected life, liberty or property interest exists. The second step is a court determination of what process is required in the situation. 2

*721 Pursuant to this analysis, the court must conclude that plaintiff did possess a constitutionally protected property interest in his employment. Property interests “are created and defined by existing rules or understandings that stem from an independent source such as state law....” Board of Regents v. Roth, 408 U.S. 564, 577, 92 S.Ct. 2701, 2709, 33 L.Ed.2d 548 (1972). Plaintiffs property interest in his employment was created by Miss.Code Ann. § 21-31-21 and § 21-31-23 (1972), which provide that civil service employees cannot be discharged except for cause. See Pinson v. Hendrix, 493 F.Supp. 772, 777 (N.D.Miss.1980) (recognizing that these sections create constitutional property interest); see also Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532, 105 S.Ct. 1487, 84 L.Ed.2d 494 (1985) (property interest created by similar Ohio statute). That being shown, the second inquiry is what due process, if any, is required.

Plaintiff has claimed that defendants failed to provide him due process prior to his suspension. 3 Though there is an abundance of case law defining the process due in many situations, the Supreme Court has not clearly defined what process, if any, is to be afforded to public employees prior to a suspension, nor has the court been able to locate any Fifth Circuit authority on this point. However, in the court’s opinion, some procedural due process normally would be required pri- or to a sixty-day suspension without pay.

In Cleveland Board of Education v. Loudermill, the Court ruled that public employees must be given a pre-termination hearing. 4 Loudermill, 470 U.S. at 542, 105 S.Ct. at 1493. The Court concluded that “an essential element of due process is that a deprivation of life, liberty, or property be ‘preceded by notice and an opportunity for a hearing appropriate to the nature of the case.’ ” Id. (citations omitted). This was described .as the “root requirement” of due process. Id. And, although the Court has not precisely defined what process is due prior to suspending a public employee, in Goss v. Lopez, 419 U.S. 565, 582, 95 S.Ct. 729, 740, 42 L.Ed.2d 725 (1975), it did rule that a student suspended, even for a period of less than ten days, is entitled to notice of the charges, an explanation of the accusations against him and an opportunity to explain his conduct prior to suspension. These cases, taken together, persuade the court that a public employee suspended without pay for sixty days is entitled to, at least, the pre-suspension protection afforded school children. See Bartlett v. Fisher, 972 F.2d 911, 915 (8th Cir.1992) (Loudermill and Goss standards apply to suspension of public employee who has property interest in retaining job).

Defendants, nevertheless, contend that Nichols’ claim is unfounded, and maintain that under the Fifth Circuit’s analysis in Shawgo v. Spradlin, 701 F.2d 470

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Bluebook (online)
848 F. Supp. 718, 1994 U.S. Dist. LEXIS 4977, 1994 WL 131094, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nichols-v-city-of-jackson-mssd-1994.