Rhett Charles v. New Orleans Police Department

CourtLouisiana Court of Appeal
DecidedSeptember 16, 2020
Docket2019-CA-0232
StatusPublished

This text of Rhett Charles v. New Orleans Police Department (Rhett Charles v. New Orleans Police Department) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rhett Charles v. New Orleans Police Department, (La. Ct. App. 2020).

Opinion

RHETT CHARLES * NO. 2019-CA-0232

VERSUS * COURT OF APPEAL NEW ORLEANS POLICE * DEPARTMENT FOURTH CIRCUIT * STATE OF LOUISIANA *******

APPEAL FROM CITY CIVIL SERVICE COMMISSION ORLEANS NO. 8736 Hearing Officer Jay Ginsberg ****** Judge Regina Bartholomew-Woods ****** (Court composed of Judge Roland L. Belsome, Judge Regina Bartholomew-Woods, Judge Paula A. Brown)

Kevin Vincent Boshea 2955 Ridgelake Drive, Suite 207 Metairie, LA 70002 COUNSEL FOR PLAINTIFF/APPELLANT

Elizabeth Robins DEPUTY CITY ATTORNEY Renee Goudeau ASSISTANT CITY ATTORNEY Donesia D. Turner CHIEF DEPUTY CITY ATTORNEY Sunni J. LeBeouf CITY ATTORNEY 1300 Perdido Street, Room 5E03 New Orleans, LA 70112 COUNSEL FOR DEFENDANT/APPELLEE

AFFIRMED SEPTEMBER 16, 2020 RBW

RLB

PAB

Appellant, a sergeant with the New Orleans Police Department, seeks review

of the Civil Service Commission’s October 5, 2018 ruling that upheld his two (2)

day suspension for violating New Orleans Police Department Rule 4: Performance

of Duty, Paragraph 4(B) Supervisory Responsibility for failure to properly

investigate a complaint of misconduct against an officer with the New Orleans

Police Department. For the reasons that follow, we affirm the Civil Service

Commission’s ruling upholding the New Orleans Police Department’s two (2) day

suspension of Appellant.

FACTUAL BACKGROUND AND PROCEDURAL HISTORY

At the time of the underlying events that gave rise to the discipline imposed,

Appellant, Sergeant Rhett Charles (“Appellant”), had been employed by the New

Orleans Police Department (“NOPD”) for twenty-eight (28) years and was a

1 permanent, classified employee. The discipline imposed on Appellant stems from

his investigation of a complaint of misconduct against NOPD Officer Taralyn

Webster (“Officer Webster”).

On March 27, 2015, Officer Webster investigated a traffic accident that

occurred at the intersection of Napoleon and South Claiborne Avenues in New

Orleans, Louisiana.1 Upon arriving at the scene of the traffic accident, Officer

Webster activated her body-worn camera and interviewed the drivers involved in

the traffic accident. Officer Webster did not make an immediate assessment of

fault for the traffic accident. While at the scene and engaged in conversation with a

driver involved in an earlier accident, Officer Webster deactivated her body-worn

camera. After the accident, Officer Webster met with a member of the City

Attorney’s Traffic Court Division, but did not supplement her report. In her report,

Officer Webster erroneously stated that the vehicle’s airbags deployed as a result

of the traffic accident and misstated the date the traffic accident occurred.

Appellant reviewed the audio and visual footage captured by Officer

Webster’s body-worn camera and interviewed Officer Webster. Appellant

concluded that the conversation regarding the relevant traffic accident had

concluded at the time when Officer Webster deactivated her body-worn camera.

Further, Appellant asserted that the policy regarding the body-worn camera was

not in effect until after the traffic accident at issue.2 Appellant was aware that

1 According to Appellant, Officer Webster was assigned to investigate two (2) separate accidents that occurred at the same intersection. 2 Policy 41.3.10 entitled, “Body-Worn Camera (“BWC”)” was revised 04/05/2015; it replaced policy 447, entitled, “Body-Worn Camera (“BWC”)”, which had been adopted on 03/11/2014

2 Officer Webster had contacted the City Attorney Traffic Division, but this

information was omitted from the report. At the time of the traffic accident, Officer

Webster had recently returned to work from injury or sick leave. Prior to Officer

Webster’s leave, the crash reports were generated on paper, not computer; in the

report at issue, she inadvertently struck an erroneous key when indicating whether

the vehicle’s airbags deployed. Appellant believed that Officer Webster’s error

deserved counseling and training rather than a sustained DI-1 violation.3 Appellant

found Officer Webster’s alleged violation of deactivating her body-worn camera

not sustained and found Officer Webster’s alleged violation of not making an

immediate determination of fault unfounded.

On May 11, 2015,4 an administrative hearing was held before NOPD

Captain (Ret.) Frederick Morton of the Alternative Response Unit. At the

conclusion of the hearing, Capt. Morton recommended that the charge against

Appellant be sustained, but that Appellant receive the discipline of a Letter of

Reprimand.

and was in effect during the pertinent time period of the instant matter. For purposes of this matter, the language contained in the subsection of the policy entitled, “Cessation of Recording” under both Policy 41.3.10 and Policy 447 are identical and state the following, in pertinent part, “Once the BWC system is activated it shall remain on and shall not be turned off until an investigative or enforcement contact or incident has concluded. For purposes of this section, conclusion of an incident has occurred when an officer has terminated contact with an individual, cleared the scene of a reported incident, or has completed transport of a civilian or an arrestee. In any instance in which cessation of the recording prior to the conclusion of an incident may be permitted, the officer must seek and obtain supervisory approval prior to deactivating the BWC.” 3 Appellant testified that “if there’s an oversight or something that just needs to be corrected we [] normally give it back to the officer and have him correct it. . . . And in [] this incident the wrongs were just an oversight that didn’t get put into the proper places.” 4 The record indicates May 11, 2016, which is clearly erroneous and the proper date should be May 11, 2015.

3 On May 13, 2015, Captain Ernest Demma (“Capt. Demma”) of NOPD’s

Field Operations Bureau issued an internal memorandum to the Superintendent of

Police, in which he stated that he disagreed with Capt. Morton’s suggested penalty

and recommended a two (2) day suspension. The (then) Superintendent of Police,

Michael Harrison agreed with Capt. Demma’s recommended discipline.

On October 26, 2015, NOPD Deputy Superintendent Paul Noel5 (“Deputy

Superintendent Noel”) reviewed Appellant’s investigation of Officer Webster and

found that Appellant’s recommendations were inconsistent with NOPD policies,

particularly the policy regarding body-worn cameras, as well as the policy

regarding the failure to assess fault and issue a traffic citation. Deputy

Superintendent Noel reviewed the footage recorded by Officer Webster’s body-

worn camera, and concluded that her body-worn camera was deactivated while she

was still speaking with a driver about an accident. For this reason, he concluded

that the corresponding violation should have been sustained. Deputy

Superintendent Noel recognized various mistakes in Appellant’s report – for

example, although Officer Webster did consult with the City Attorney regarding

the March 27, 2015 traffic accident, Appellant neglected to note that in his

investigation report; Appellant contended that this was merely an oversight.

Deputy Superintendent Noel concluded that Appellant’s investigation and

recommendations were negligent. As a result, on November 9, 2015, Deputy

Superintendent Noel initiated a Public Integrity Bureau (“PIB”) investigation

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