Perry Puckett v. Cabinet for Health and Family Services

CourtKentucky Supreme Court
DecidedApril 27, 2021
Docket2019 SC 0282
StatusUnknown

This text of Perry Puckett v. Cabinet for Health and Family Services (Perry Puckett v. Cabinet for Health and Family Services) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Perry Puckett v. Cabinet for Health and Family Services, (Ky. 2021).

Opinion

RENDERED: APRIL 29, 2021 TO BE PUBLISHED

Supreme Court of Kentucky 2019-SC-0282-DG

PERRY PUCKETT APPELLANT

ON REVIEW FROM COURT OF APPEALS V. NO. 2017-CA-1060 FRANKLIN CIRCUIT COURT NO. 10-CI-01144

CABINET FOR HEALTH AND FAMILY APPELLEES SERVICES AND KENTUCKY PERSONNEL BOARD

OPINION OF THE COURT BY JUSTICE KELLER

AFFIRMING

Perry Puckett was terminated from his employment with the

Commonwealth of Kentucky Cabinet for Health and Family Services (CHFS) in

2009 for excessive and inappropriate personal email usage. After protracted

litigation through multiple levels of appeals, the Franklin Circuit Court

reversed his termination. CHFS appealed to the Court of Appeals which

reversed the circuit court. This Court granted discretionary review, and after a

careful review of the record and pertinent authority, we affirm the Court of

Appeals.

I. BACKGROUND

In 2009, Puckett was employed by CHFS as a Disability Adjudicator III –

Trainer. He had been employed by CHFS for over a decade when he was terminated in 2009 for excessive and inappropriate email usage including

sending emails that contained graphic sexual comments and photos,

unprofessional language, and derogatory comments about coworkers and

supervisors. Significantly, Puckett’s termination letter was signed by Jay Klein,

a Division Director in the Division of Employee Management at CHFS,

purportedly on behalf of J.P. Hamm, CHFS’s Human Resources Director. Klein

signed Hamm’s name, followed by a diagonal slash and his own initials (JK).

Hamm had been appropriately delegated appointing authority by the Secretary

of CHFS, but Klein had not.1 Because the question before us does not involve

the merits of Puckett’s termination, we will not discuss the underlying facts in

great detail. Instead, we will focus our discussion on the long procedural

history of this case.

After receiving the termination letter, Puckett timely appealed his

termination to the Kentucky Personnel Board (the Board). A hearing was held

before a hearing officer at which several CHFS employees testified, including

Klein. During CHFS’s opening statement, counsel for CHFS stated that Klein

made the final determination to terminate Puckett. Sean Estep, Human

Resources Administrator for CHFS, testified at the hearing and twice referred to

Klein as the appointing authority charged with making termination decisions.

Klein himself testified that he was the appointing authority for disciplinary

actions and that part of his job was to review final disciplinary actions and

1 In this Opinion, we assume without deciding that Klein did not possess the

requisite authority to terminate Puckett.

2 “sign off” on said actions. No witness was asked, and no witness testified as to,

who actually signed Hamm’s name on Puckett’s termination letter. However,

during his testimony, Klein acknowledged signing Hamm’s name, followed by

his own initials, on another document relating to a different employee, and this

document was admitted into evidence, by stipulation, at the hearing.

After an evidentiary hearing, the hearing officer issued a recommended

order finding that Puckett’s punishment was disproportionately harsh and

recommending that the termination be reduced to a 30-day suspension. CHFS

filed exceptions to the hearing officer’s recommended order, and Puckett did

not. The Board rejected the hearing officer’s recommended order and instead

imposed Puckett’s termination. Puckett then timely petitioned the Franklin

Circuit Court for review of his termination.

While the case was pending in Franklin Circuit Court, Puckett’s attorney

learned, through discovery in a separate, unrelated case, that Klein had

actually signed Hamm’s name to Puckett’s termination letter. Also while

Puckett’s case was pending, it became clear that Klein did not have the

requisite appointing authority to terminate CHFS employees. Based on this

new knowledge, Puckett moved to amend his complaint in circuit court to

include a claim that Puckett’s termination was null and void because the

person who signed the termination document lacked appointing authority to

terminate him. He further moved for a stay of the proceedings in circuit court

so that the matter could be remanded to the Board for consideration of whether

his termination was void. The circuit court granted both of these motions.

3 CHFS then filed both a petition for a writ of prohibition and an

interlocutory appeal in the Court of Appeals. The writ petition asked the Court

of Appeals to prohibit the circuit court from enforcing its order remanding the

case back to the Board. The Court of Appeals denied the writ petition holding

that the circuit court acted within its jurisdiction in remanding the case back

to the Board. Ky. Cabinet for Health & Family Servs. v. Puckett, No. 2012-CA-

002195-OA (Ky. App. June 10, 2013). In the interlocutory appeal, the Court of

Appeals held that Puckett’s “amended complaint properly asserts a claim for

declaratory relief which is not barred by the doctrine of sovereign immunity.”

Cabinet for Health & Family Servs. v. Puckett, No. 2012-CA-002165-MR, 2014

WL 689094, at *1 (Ky. App. Feb. 21, 2014).

Following the Court of Appeals’ rulings, the Board took up the case on

remand from the circuit court. A hearing officer held another evidentiary

hearing and issued a recommended order. The hearing officer concluded that

the Board had no authority to decide whether Puckett’s termination was void

due to Klein’s lack of appointing authority because there was no evidence of

fraud or misconduct on the part of CHFS and the issue had not been raised or

preserved before the Board previously. Puckett filed exceptions to the hearing

officer’s recommended order; however, the Board adopted the hearing officer’s

recommended order in its entirety.

Puckett then moved the circuit court to re-activate the case and for leave

to file another amended complaint to include review of the Board’s most recent

order. An agreed order was entered lifting the stay and allowing the amended

4 complaint to be filed. After briefing and argument, the circuit court entered an

opinion and order reversing the Board’s original order terminating Puckett,

finding that the Board lacked substantial evidence to terminate Puckett and

that its decision was arbitrary. Interestingly, the circuit court never addressed

the issue on which it remanded the case to the Board, whether Puckett’s

termination was void due to Klein’s lack of appointing authority. CHFS

appealed to the Court of Appeals.2

The Court of Appeals reversed the circuit court holding, in short, that the

circuit court substituted its own judgment for that of the Board and that

substantial evidence supported Puckett’s termination. Relevant to this appeal,

the Court of Appeals declined to address Puckett’s argument that his

termination was void because Puckett did not properly preserve that argument

for appeal and CHFS did not commit fraud or misconduct.

Puckett filed a motion for discretionary review with this Court which we

granted to determine, essentially, whether the circuit court’s remand to the

Board was proper.

II. STANDARD OF REVIEW

This case primarily involves the interpretation of Kentucky Revised

Statute (KRS) 13B.150.

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Perry Puckett v. Cabinet for Health and Family Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/perry-puckett-v-cabinet-for-health-and-family-services-ky-2021.