Rick Benningfield in His Official Capacity as Taylor County Jailer v. Jerry Fields

CourtKentucky Supreme Court
DecidedSeptember 26, 2019
Docket2018-SC-0292
StatusUnpublished

This text of Rick Benningfield in His Official Capacity as Taylor County Jailer v. Jerry Fields (Rick Benningfield in His Official Capacity as Taylor County Jailer v. Jerry Fields) 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.

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Rick Benningfield in His Official Capacity as Taylor County Jailer v. Jerry Fields, (Ky. 2019).

Opinion

RENDERED: SEPTEMBER 26, 2019 TO BE PUBLISHED

2018-SC-000292-DG

RICK BENNINGFIELD, INDIVIDUALLY AND APPELLANTS IN HIS OFFICIAL CAPACITY AS TAYLOR COUNTY JAILER; EDDIE “HACK” MARCUM, INDIVIDUALLY AND IN HIS OFFICIAL CAPACITY AS TAYLOR COUNTY JAILER; TAYLOR COUNTY FISCAL COURT; EDDIE ROGERS, TAYLOR COUNTY JUDGE EXECUTIVE; JAMES JONES, MAGISTRATE; JOHN GAINES, MAGISTRATE; TOMMY CORBIN, MAGISTRATE; MATT PENDLETON, MAGISTRATE; ED GORIN, MAGISTRATE; AND RICHARD PHILLIPS, MAGISTRATE

ON REVIEW FROM COURT OF APPEALS V. CASE NO. 2015-CA-001975 TAYLOR CIRCUIT COURT NO. 13-CI-00144

JERRY FIELDS APPELLEE

OPINION OF THE COURT BY JUSTICE KELLER

AFFIRMING IN PART, REVERSING IN PART AND REMANDING

In this wrongful termination case, the Taylor Circuit Court granted

summary judgment in favor of Rick Benningfield, individually and in his official

capacity as Taylor County Jailer; Eddie “Hack” Marcum, individually and in his

official capacity as Taylor County Jailer; Taylor County Fiscal Court; Eddie Rogers, Taylor County Judge Executive; James Jones, Magistrate; John

Gaines, Magistrate; Tommy Corbin, Magistrate; Matt Pendleton, Magistrate; Ed

Gorin, Magistrate; and Richard Phillips, Magistrate. The Court of Appeals

reversed, holding that KRS 342.197 constitutes a waiver of sovereign immunity

against a governmental employer and that genuine issues of material fact

existed, thereby precluding summary judgment. Having reviewed the record

and the applicable law, we now affirm in part and reverse in part.

I. BACKGROUND

On October 23, 2008, Jerry Fields was hired as a deputy jailer with the

Taylor County Detention Center (hereinafter, the “Jail”). His effective date of

employment was November 1, 2008. At that time, Rick Benningfield served as

the Taylor County Jailer.

On June 11, 2009, Fields tore the rotator cuff of his right shoulder while

attempting to restrain an inmate. Surgery to repair the tear took place in

August 2009. Several months later, Fields’s doctor informed him that there

was a second deeper tear in the same shoulder and recommended a second

surgery. After consulting with specialists and determining that his chance of

improvement was slight, Fields declined to undergo this additional surgery.

His doctor released him to perform only light duty work and restricted his

lifting to twenty pounds or less, with no repetitive or overhead work and no use

of power tools that vibrated. He was also directed to avoid those combat or

restraint situations typically associated with the work of a corrections officer.

Chief Deputy Jailer Kevin Wilson informed Fields that no such light duty work

2 was available. Fields was never released to return to regular work and his

restrictions are permanent.

During Fields’s medical leave, he was required to regularly update his

employer on his medical status. Wilson testified at his deposition that he

believed Fields came to the Jail on a couple of occasions after his injury, but

Wilson could not recall speaking with Fields. Benningfield testified at his

deposition that he could recall Fields visiting the Jail “a couple times” after his

injury. He testified that he would contact Sherry Kerr, an employee with the

county judge’s office who typically handled the medical excuses, on a monthly

basis to check on Fields’s status.

Fields, on the other hand, testified at his deposition that he visited the

Jail after every doctor’s visit and informed Benningfield and Wilson of his

status. According to Fields, during the last two or three visits prior to his

termination, he felt he was not welcome at the Jail. For example, he recalled

one conversation in which Benningfield informed Fields that he would love to

fire him but he could not do so because Fields was receiving workers’

compensation. During that conversation, Benningfield noted that he was

forced to fill Fields’s position with part-time employees. Fields also referenced

an earlier conversation with Wilson about Fields’s demotion from sergeant to

deputy. Fields had been promoted to sergeant in April 2009 for a probationary

period and with a deputy’s pay rate. After his injury, he was informed by

Wilson that the Jail had decided to keep him as a deputy, rather than a

sergeant. According to Fields, Wilson explained that he could do this because

3 “I’m sitting here and you’re sitting over there. I can do this.” Fields also

testified that the Jail stopped calling to check on him once it became known

that he required surgery.

Fields’s medical leave expired on March 10, 2010. Chief Deputy Wilson

testified at his deposition that he was contacted on that date by Kerr, the

employee who typically handled the medical excuses. Kerr notified Wilson of

Fields’s expired medical excuse and her unsuccessful attempts to contact

Fields. She asked if Wilson had attempted to contact Fields, and Wilson

replied that it was not his job to track down Fields and he was ready to

terminate him. The Jail then sent a notice of termination letter to Fields, dated

March 15, 2010 and signed by Wilson. The letter was sent via U.S. Mail (first

class). The body of the letter stated, in full:

Notice of Termination effective as of 3/10/2010 1. Doctors excuse expired as of 03-10-2010 2. FMLA leave[:] you are not eligible for this because You [sic] had not worked 1 year prior to leave starting. 3. Cervical neck injury you are claiming as your injury At [sic] this time is not related to the shoulder Injury [sic] that workman comp, claim started with 4. No attempt has been made to contact the Taylor County Detention Center 5. Failure to contact employer on status of injury This letter is also to inform you that your health insurance, Dental and life insurance will expire on 03-31-2010. Any further questions need to be addressed to the County Attorney.

After receiving the letter on March 20, 2019, Fields contacted the County

Judge Executive, Eddie Rogers. Rogers referred Fields to Benningfield and the

county attorney. Fields did not follow up with Benningfield or the county

attorney, but instead spoke with Wilson, who reiterated the reasons for 4 termination cited in the letter. Wilson also referred Fields to the county

attorney, but Fields did not speak with the county attorney, nor did Fields

request a hearing to dispute his termination.1

Fields received workers’ compensation for his injuries, and that claim

was settled in 2011. Fields then filed suit against Appellants in the United

States District Court for the Western District of Kentucky, alleging Fourteenth

Amendment due process violations, as well as wrongful termination and

retaliation claims arising under state law. See Fields v. Benningfield, 2012 WL

5497918 (W.D. Ky. Nov. 13, 2012). The District Court granted summary

judgment for the defendants in that case. That court dismissed the due

process claim, noting that Fields had been adequately notified of the charges

against him and his right to request a hearing. However, the court declined to

exercise jurisdiction over the remaining state law claims. It therefore dismissed

the due process claim with prejudice and dismissed the state law wrongful

termination and retaliation claims without prejudice. The Court of Appeals for

the Sixth Circuit affirmed this decision.

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