Oldridge v. Layton

CourtCourt of Appeals for the Tenth Circuit
DecidedMay 2, 2024
Docket22-3284
StatusUnpublished

This text of Oldridge v. Layton (Oldridge v. Layton) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oldridge v. Layton, (10th Cir. 2024).

Opinion

Appellate Case: 22-3284 Document: 010111042161 Date Filed: 05/02/2024 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT May 2, 2024 _________________________________ Christopher M. Wolpert Clerk of Court LANCE OLDRIDGE,

Plaintiff - Appellee,

v. No. 22-3284 (D.C. No. 6:21-CV-01284-EFM-KGG) ROBERT LAYTON; ANNA HATTER, (D. Kan.)

Defendants - Appellants,

and

CITY OF WICHITA, KANSAS; GORDON RAMSAY; WANDA GIVENS; JOSE SALCIDO,

Defendants.

LANCE OLDRIDGE,

v. No. 23-3070 (D.C. No. 6:21-CV-01284-EFM-KGG) WANDA GIVENS; JOSE SALCIDO, (D. Kan.)

CITY OF WICHITA, KANSAS; ROBERT LAYTON; GORDON RAMSAY; ANNA HATTER,

Defendants. Appellate Case: 22-3284 Document: 010111042161 Date Filed: 05/02/2024 Page: 2

_________________________________

ORDER AND JUDGMENT* _________________________________

Before HARTZ, TYMKOVICH, and ROSSMAN, Circuit Judges. _________________________________

Lance Oldridge sued the City of Wichita and several of its employees after his

dismissal from the police department, alleging First Amendment retaliation. The

government defendants appeal the district court’s denial of qualified immunity. We

accept as true the district court’s determination of the facts relevant to qualified

immunity at this stage of the case. And the district court’s findings at this stage

support Oldridge’s claim that he was terminated for exercising his First Amendment

rights and that those rights were clearly established. His claims based on retaliatory

investigation, however, are not supported by clearly established law, so the

defendants to that claim are entitled to qualified immunity.

Accordingly, we affirm in part and reverse in part, and remand for further

proceedings.

I. Background

In its order denying qualified immunity, the district court found the following

facts to be in dispute.

* This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. 2 Appellate Case: 22-3284 Document: 010111042161 Date Filed: 05/02/2024 Page: 3

Lance Oldridge was a longstanding Wichita Police Department (WPD) veteran

who was assigned to the Professional Standards Bureau and later the WPD academy.

He was terminated in 2019 after a series of disputes with his supervisors.

The controversy arose as follows. In 2019, the Wichita Eagle published an

article quoting statements that WPD Chief Gordon Ramsay had made in a deposition

in a case related to questionable police practices. According to that article, Chief

Ramsay was concerned that police officers—including, potentially, Oldridge—had

engaged in misconduct during criminal investigations. The article reported that Chief

Ramsay had testified that he had reassigned several officers as a result. Although not

named directly, those officers impliedly included Oldridge.

In response to the article, Chief Ramsay issued a public statement claiming

that the reassigned officers “committed no legal or WPD internal violations.” Order

at 3.

Based on that public statement, Oldridge believed that Chief Ramsay had been

caught in a lie: he had testified in his deposition that police officers had committed

WPD violations, but he had said the opposite in the public statement issued after the

deposition. Accordingly, Oldridge delivered a dossier containing Chief Ramsay’s

deposition, his public statement, and copies of Kansas statutes pertaining to false

communications to the Sedgwick County District Attorney. This supposedly

provided a basis to support a prosecution of Chief Ramsay for violating Kansas law.

The district attorney, after reviewing the materials, sent Oldridge an email

opining that Chief Ramsay had not committed a crime. Undeterred, Oldridge sent a

3 Appellate Case: 22-3284 Document: 010111042161 Date Filed: 05/02/2024 Page: 4

similar packet to the sheriff, although he apprised the sheriff of the district attorney’s

negative review of his complaint. After consulting with the district attorney, the

sheriff informed Oldridge that he believed Chief Ramsay had not committed perjury

and that he would not launch an investigation. He also contacted Chief Ramsay to

inform him of Oldridge’s efforts.

Chief Ramsay told his staff about Oldridge’s accusations. WPD deputy chiefs

Jose Salcido, Anna Hatter, and Wanda Givens met with the district attorney to

discuss the matter. After that meeting, they decided that Deputy Salcido and Deputy

Givens would request an internal investigation into Oldridge’s conduct.

At the beginning of the investigation, Oldridge was told that he had failed to

inform the sheriff of his prior communications with the district attorney. But

Oldridge produced documents showing that this accusation was false, since he had in

fact informed the sheriff of his prior correspondence with the district attorney. The

department nonetheless suspended Oldridge without pay pending the investigation

and took the unusual step of confining him to his residence during the workweek.

Although Oldridge’s documents refuted the investigation’s original basis, the

WPD amended its investigation to add a general allegation that he had engaged in

conduct intended to discredit the WPD. At the investigation’s conclusion, Deputy

Hatter recommended terminating Oldridge. Her memorandum to City Manager

Brandon Layton discussed Oldridge’s statements to the district attorney and the

sheriff, but suggested that the basis for termination centered on his allegedly

4 Appellate Case: 22-3284 Document: 010111042161 Date Filed: 05/02/2024 Page: 5

derogatory and debasing statements about the police chief to his coworkers, his

untruthfulness, and his breach of a prior confidentiality agreement.

Oldridge filed a grievance protesting this outcome, which led to an arbitrator’s

recommendation of reinstatement. Layton rejected that recommendation and

terminated Oldridge. After Oldridge’s appeal, a state court affirmed the termination

decision, finding it was supported by substantial evidence and was not arbitrary and

capricious.

Oldridge filed this suit in federal court, alleging claims under the First and

Fourteenth Amendments, Title VII, and the Kansas Act Against Discrimination. The

district court denied summary judgment on Oldridge’s First Amendment retaliation

claims. The defendants only challenge the constitutional claims in this interlocutory

appeal.

II. Analysis

The defendants contend the district court erred in denying their claim to

qualified immunity.

A. Legal Framework

1. Qualified Immunity

“A § 1983 defendant’s assertion of qualified immunity is an affirmative

defense that creates a presumption that the defendant is immune from suit.” Truman

v. Orem City, 1 F.4th 1227, 1235 (10th Cir. 2021) (brackets internal quotation marks

omitted). The doctrine is designed to shield “officials from civil liability so long as their

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Oldridge v. Layton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oldridge-v-layton-ca10-2024.