Randolph v. City of Richmond

66 Va. Cir. 102, 2004 Va. Cir. LEXIS 342
CourtRichmond County Circuit Court
DecidedOctober 7, 2004
DocketCase Nos. LS-2039-4 and LS-2043-4
StatusPublished
Cited by1 cases

This text of 66 Va. Cir. 102 (Randolph v. City of Richmond) is published on Counsel Stack Legal Research, covering Richmond County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Randolph v. City of Richmond, 66 Va. Cir. 102, 2004 Va. Cir. LEXIS 342 (Va. Super. Ct. 2004).

Opinion

By Judge Randall G. Johnson

In each of these cases, Debbie A. Randolph, a City of Richmond employee, asks the court to overturn the decision of the city’s Director of Human Resources that her complaint is non-grievable under the city’s Personnel Rules for the Classified Service. In each case, the issue is whether a “written counseling,” as that term is used in the Rules, is a disciplinaiy action. If it is, the complaints are grievable. If it is not, the complaints are not grievable. The court holds that the complaints are grievable.

To understand the reasons for the court’s decision, some background is necessary. Section 1.1 (26) of the city’s Personnel Rules contains the following definition:

Counseling — A verbal statement, which may be followed in written form, made to an employee intended to improve job performance or job related behavior. Counseling is not a disciplinary action and is not grievable.

On January 13, 2004, this court, through the author of this opinion, decided the appeal of Mark D. Hatchett, a city employee. Hatchett had filed a complaint concerning a change in his performance evaluation from “Exceptional” to “Successfully Meets Expectations.” The reason given for the change by Hatchett’s supervisor was that Hatchett had received a “Formal Counsel and Assistance,” the same as a written counseling, concerning a work-related incident.

[103]*103Hatchett filed a complaint with the city, which was determined to be non-grievable. He appealed that decision to this court. At argument, Hatchett took the position that, since the written counseling was being used to deprive him of an employment benefit, an “Exceptional” rating, it was discipline. The city, citing its Rules, argued that the counseling was not grievable. In Hatchett v. City of Richmond, 63 Va. Cir. 554 (2004), the court expressed concern over the city’s position. With regard to the statement in the Rules that written counselings are not discipline, the court said:

The court is not bound by that statement. Under the city’s personnel rules, disciplinary actions are grievable. The city cannot deprive an employee of the right to grieve a disciplinary action simply by saying that the action is not discipline. If the action is discipline, it is discipline regardless of the city’s characterization of it.

63 Va. Cir. at 555.

In spite of the court’s concern, the complaint was held to be non-grievable. That decision, however, was made not because the written counseling was not discipline, but because Hatchett had not complained about it within the time limit set by the Rules, the court specifically stating that it “need not decide whether the ‘Formal Counsel and Assistance’ given to Hatchett in this case is discipline.” Id1

On February 13, 2004, Judge Hughes of this court decided the appeal of Everett M. Fields, another city employee. Like Hatchett, Fields had been given a written counseling, this time variously called a “Letter of Counseling” or “counseling memorandum,” and had filed a complaint with the city. Also like Hatchett, his complaint was determined by the Director of Human Resources to be non-grievable. On appeal, after noting Fields’ argument that “the counseling memorandum is for all intents and purposes a reprimand and should be treated as such and thus grievable under the personnel rules,” Everett M. Fields v. City of Richmond, Case No. LM-2598-1 (Slip Op. at 1),2 [104]*104and after discussing the factual situation in Hatchett, which had been cited by Fields as support for his argument, Judge Hughes said:

Fields contends that since the City has said the memorandum will go into his personnel file for fixture reference, this amounts to disciplinary action. The fact that the counseling memorandum will be placed in Fields’ file for reference in the event of future infractions does not suggest that presently Fields has been made subject to employment discipline. There is no linkage to anything of an employment discipline presently as was the case in Hatchett..'

Id. at 2 (emphasis added).

Judge Hughes held that Fields’ complaint was not grievable.

On March 4, 2004, the court, again through the author of this opinion, decided an appeal involving the present appellant, Debbie A. Randolph. That appeal involved an incident that occurred on December 16, 2003. On that date, Randolph was involved in a “confrontation” with a fellow employee for which she received á written counseling. Randolph filed a complaint, and, when it was determined to be non-grievable, she appealed to this court. At the time of the appeal, no other employment action, such as changing Randolph’s performance evaluation, had occurred. In other words, there was no “linkage,” as that term was. used by Judge Hughes in Fields, between the written counseling and any adverse employment decision. At the hearing in this court, the city argued, and the court ruled from the bench, that the written counseling was not grievable.

The above background sets the stage for Randolph’s present appeals. In LS-2039-4, Randolph Complains about her performance evaluation dated July 7, 2004. As was the case with Hatchett, Randolph was rated by her immediate supervisor as “Exceptional.” When the evaluation moved through the chain of command, however, it was changed to “Successfully Meets Expectations.” As was also true with Hatchett, Randolph was told that the reason for the change was the presence of a written counseling in her personnel file; specifically, the counseling that she had unsuccessfully challenged in her earlier complaint to the city and appeal to this court. In fact, between the time of Hatchett’s appeal and Randolph’s evaluation, the city had enacted Ordinance No. 2004-110-136, providing that “[n]o rating of ‘Exceptional’ shall be given to an employee who received a written counseling... during the rating period.”

In LS-2043-4, Randolph appeals a non-grievability determination concérning a later “counseling memorandum” which, though not relied on by the city as a reason for the change in her July evaluation, also occurred during [105]*105the evaluation period. Because Randolph has timely challenged the latest written counseling, and because the city has now used the earlier written counseling to deprive her of an “Exceptional” performance rating, thus providing the “linkage” that was missing in the Fields case before Judge Hughes’ and in Randolph’s earlier appeal, the court believes that the question of whether the city’s use of written counselings constitutes discipline is now squarely before it. The court concludes that such counselings are discipline..

As was said in Hatchett, the court is not bound by the city’s statement in its Personnel Rules that written counselings are not discipline. The fact that Richmond maintains a grievance procedure for its classified workforce is not the result of the city’s benevolence. It is required by law. Va. Code § 15.1-1506 provides, in part:

Notwithstanding any other provision of law to the contrary, general or special, every locality which has more than fifteen employees shall have a grievance procedure for its employees that affords an immediate and fair method for the resolution of disputes which may arise between the public employer and its employees. ...

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Cite This Page — Counsel Stack

Bluebook (online)
66 Va. Cir. 102, 2004 Va. Cir. LEXIS 342, Counsel Stack Legal Research, https://law.counselstack.com/opinion/randolph-v-city-of-richmond-vaccrichmondcty-2004.