Oberg v. City of Billings

674 P.2d 494, 207 Mont. 277, 1983 Mont. LEXIS 866, 38 Empl. Prac. Dec. (CCH) 35,518
CourtMontana Supreme Court
DecidedDecember 22, 1983
Docket82-284
StatusPublished
Cited by13 cases

This text of 674 P.2d 494 (Oberg v. City of Billings) is published on Counsel Stack Legal Research, covering Montana Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oberg v. City of Billings, 674 P.2d 494, 207 Mont. 277, 1983 Mont. LEXIS 866, 38 Empl. Prac. Dec. (CCH) 35,518 (Mo. 1983).

Opinions

MR. JUSTICE SHEA

delivered the opinion of the Court.

Bruce P. Oberg, a Billings police officer appears from a summary judgment of the Yellowstone County District Court upholding a determination of the Billings Police Commission that Officer Oberg was guilty of insubordination for refusing a direct order to take a polygraph examination. The trial court enforced the Police Commission’s recommendation that Officer Oberg be suspended without pay for 15 days, followed by a six-month probationary period. Officer Oberg challenges the constitutionality of that part of a statute which provides that only employees of public law enforcement agencies can be compelled to take polygraph examinations.

Officer Oberg has challenged the statute on five constitutional grounds. He claims that the exception for public law enforcement agencies violates his constitutionally guaranteed right to equal protection of the laws, right to privacy, freedom from unlawful search and seizure, freedom from compelled self-incrimination and due process.

We reverse the trial court’s summary judgment and declare that Section 39-2-304(2), MCA, is an unconstitutional violation of public law enforcement agency employees’ right to equal protection of the laws. Although we believe the statute also offends the equal protection clause under the Fourteenth Amendment to the United States Constitution, we limit our holding to the conclusion that the statute offends the equal protection clause under Art. II, Section 4, of our own constitution. We therefore limit our discussion to the equal protection issue and do not reach the remaining [279]*279issues.

We summarize the agreed statement of facts submitted to the trial court. Bruce P. Oberg, a Billings police officer arrested a citizen who later filed a complaint with the police department claiming that Officer Oberg struck him after he was arrested and handcuffed. As a part of the police department’s internal investigation of the citizen’s complaint, the police chief wrote to Oberg on July 24, 1979, and formally ordered Oberg to submit to a polygraph examination. On July 27, 1979, Oberg responded by letter informing the police chief that he refused to submit to the polygraph examination. Officer Oberg asserted that mandatory compliance with the police chiefs order violated various constitutional rights guaranteed by both the United States and Montana Constitutions.

The Chief of Police then filed charges against Officer Oberg and brought the matter before the Billings Police Commission. The Chief of Police charged among other things that Officer Oberg’s failure to comply with the order to submit to a polygraph examination constituted insubordination.

The Billings Police Commission held a hearing and later on October 15, 1979, found Officer Oberg guilty of insubordination and ordered Officer Oberg be disciplined by removal from duty for fifteen days with forfeiture of all wages for that period of time together with the imposition of a six month probationary period.

On October 19, 1979, the acting city administrator issued an order enforcing the decision of the police commission. On December 11, 1979, Oberg filed a petition in Yellowstone County District Court for judicial review. After the pleadings were filed both Oberg and the City moved for summary judgment on the ground that no issues of material fact were presented to the trial court for resolution. The trial court granted the City’s motion for summary judgment and held that the polygraph provision as applied to police officers was constitutional.

[280]*280The statute involved, Section 39-2-304(1), MCA, provides:

“Lie detector tests prohibited — exception.
“(1) No person, firm, corporation, or other business entity or representative thereof shall require as a condition for employment or continuation of employment any person to take a polygraph test or any form of a mechanical lie detector test. A person who violates this section is guilty of a misdemeanor.
“(2) This section shall not apply to public law enforcement agencies.”

We hold that Subsection (2) denies employees of public law enforcement agencies equal protection of the law in violation of state constitutional provisions. The Montana Constitution, Art. II, Section 4, states:

“Individual dignity. The dignity of the human being is inviolable. No person shall be denied the equal protection of the laws. Neither the state nor any person, firm, corporation, or institution shall discriminate against any person in the exercise of his civil or political rights on account of race, color, sex, culture, social origin or condition, or political or religious ideas.”

In upholding the exception that permits employers to give polygraph tests to public law enforcement agencies, the trial court applied a strict scrutiny analysis. The trial court assumed that because a right of privacy violation was alleged, a strict scrutiny analysis was required. However, we have held that a mere allegation that a fundamental right is burdened is insufficient to trigger a strict scrutiny analysis. Godfrey v. Mont. State Fish & Game Com’n. (Mont. 1981), 631 P.2d 1265, 38 St.Rep. 661. Here, the plaintiff has challenged a general legislative classification but has failed to lay the groundwork for a claim that the classification either burdened a fundamental right or involved a suspect criteria. Examples of fundamental rights include privacy, freedom of speech, freedom of religion, right to vote and right to interstate travel. Examples of suspect criteria are wealth, race, nationality and alienage.

[281]*281Plaintiff has not gone beyond the mere allegation that the required polygraph test violated his right to privacy. The accusations against plaintiff unquestionably involved his work as a police officer, and as such he could not reasonably claim that the police department could not investigate his actions based upon a citizen’s complaint. He could be questioned and otherwise required to cooperate with an interdepartmental investigation based on the citizen’s complaint. Because we feel plaintiff has failed to show that any fundamental right was substantially abridged by the statute, we determine that it was unnecessary to apply the strict scrutiny analysis to the challenged part of the statute. However, even under the less vigorous test requiring that a classification must bear a rational relationship to a legitimate governmental purpose, Section 39-2-304(2), MCA, still must fail a challenge under the equal protection clause of our state constitution.

This Court cannot determine whether this classification bears a rational relationship to a legitimate governmental purpose because there is no expressed purpose for the classification on the face of the statute or in the statute’s legislative history. For that reason, the challenged part of the statute is overbroad and vague on its face, and an unconstitutional violation of the plaintiff’s right to equal protection of the law.

Subsection (1) of the statute is a directive to all employers in this state — private and public — telling them that they cannot subject a prospective employee or an employee to polygraph examination, either as a condition of gaining employment or as a condition of retaining employment. The intent is crystal clear.

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Oberg v. City of Billings
674 P.2d 494 (Montana Supreme Court, 1983)

Cite This Page — Counsel Stack

Bluebook (online)
674 P.2d 494, 207 Mont. 277, 1983 Mont. LEXIS 866, 38 Empl. Prac. Dec. (CCH) 35,518, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oberg-v-city-of-billings-mont-1983.