Spradling v. Hutchinson

253 S.E.2d 371, 162 W. Va. 768
CourtWest Virginia Supreme Court
DecidedMarch 19, 1979
Docket13685
StatusPublished
Cited by18 cases

This text of 253 S.E.2d 371 (Spradling v. Hutchinson) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Spradling v. Hutchinson, 253 S.E.2d 371, 162 W. Va. 768 (W. Va. 1979).

Opinions

Harshbarger, Justice:

Thirteen applicants were selected by the Police Civil Service Commission for the City of Charleston for final appointment to the Charleston Police Department and were to be sworn in November 4, 1974. But on November 1 the Fraternal Order of Police petitioned for an injunction against their induction. A temporary injunction was issued but then, after hearings, permanent injunction was refused by the Kanawha County Circuit Court.

The Fraternal Order of Police appealed, contending as it did in the trial court, that the applicants did not comply with W.Va. Code, 8-14-12.1

[770]*770Specifically, the FOP alleges that the applications of the thirteen failed to comply with a mandate of Code, 8-14-12, that applicants must state under oath or affirmation certain information;2 two applicants did not meet residency requirements;3 and one was older than allowed.

We find that the application forms signed by the thirteen meet the statutory requirement of oath or affirmation. The forms contained this language: “I HEREBY CERTIFY THAT THERE ARE NO WILLFUL MISREPRESENTATIONS IN, OR FALSIFICATIONS OF, THE ABOVE STATEMENTS AND ANSWERS TO QUESTIONS.” Then followed the signature lines.

[771]*771An oath or affirmation is a subscription to the truth of that to which it is made. See, In re Rice, 35 Ill. App.2d 79, 181 N.E.2d 742, (1962); Greenwald v. State, 221 Md. 235, 155 A.2d 894 (1960); and Spangler v. District Court of Salt Lake County, 104 Utah 584, 140 P.2d 755 (1943).

In State v. Nuckols, 152 W. Va. 736, 166 S.E.2d 3 (1968), we said: “The word ‘oath’ in this state includes both swearing and affirming....” 152 W. Va. at 748, 166 S.E.2d at 11.4 The Random House Dictionary (1973), defines ‘certify’ as “1. to attest to or vouch for in writing ....” It defines ‘affirm’ — “1. to state or assert positively; maintain as true ... 2. to confirm or ratify ... 4. to declare solemnly before a court or magistrate, but without oath.” We discern no difference between an affirmation of truth, and a certification of truth. They both vouch for truthfulness.

The second issue in this appeal is the constitutionality of the residency requirement of Code, 8-14-12.5 The general rule is that statutes regulating appointments under civil service are mandatory and must be strictly complied with and construed. Cawley v. Board of Trustees, 138 W. Va. 571, 76 S.E.2d 683 (1953). In particular, we have held that the police civil service commission “owes its creation and existence to statute. It has no inherent powers... [but] only such powers as are conferred upon it by statute, either expressly or by necessary or fair implication.” State ex rel. City of Huntington v. Lombardo, 149 W. Va. 671, 681, 143 S.E.2d 535, 542 (1965). See also: Miller v. City of Morgantown, W. Va., 208 S.E.2d 780 [772]*772(1974) and State ex rel. City of Charleston v. Hutchinson, 154 W. Va. 585, 176 S.E.2d 691 (1970).

Thus, the Charleston Police Civil Service Commission cannot legally act beyond the powers bestowed upon it by statute [8-14-12] and must strictly abide by the requirements in that law. Since the statute clearly states that an applicant must have been a resident of the city to which he is applying, for at least one year prior to the date of his application, the question is whether the commission acted ultra vires by certifying applicants for police officers who did not meet the residency requirement of the statute, or whether the requirement itself is void, as contended by the appellees.

Residence requirements have been discussed in numerous cases since Shapiro v. Thompson, 394 U.S. 618 (1969), when the United States Supreme Court recognized the right to travel as a fundamental constitutional right and struck down a state statute requiring one year residency prior to seeking welfare assistance. The Court found that the durational requirement divided welfare applicants into two groups “indistinguishable from each other except that one is composed of residents who have resided a year or more, and the second of residents who have resided less than a year, in the jurisdiction. On the basis of this sole difference the first class is granted and the second class is denied welfare aid upon which may depend the ability of the families to obtain the very means to subsist — food, shelter, and other necessities of life.” 394 U.S. at 627. Because the requirement infringed upon the right to travel, a fundamental constitutional right, by denying welfare benefits to those who had exercised it, the Court applied the compelling state interest test, and then held the requirement violated the equal protection clause because there was no such interest. Id. at 634.

After Shapiro, the Court found that durational residency requirements for eligibility to vote6 and for hospi[773]*773tal and medical services7 unconstitutionally infringe upon an individual’s fundamental right to travel.

Then, in McCarthy v. Philadelphia Civil Service Commission, 424 U.S. 645 (1976), a Philadelphia municipal regulation requiring that city employees be residents of the city, was upheld. Emphasizing the novelty of the particular question it must decide — the validity of a requirement that a person be a resident at the time of his application, the Court said:

We have previously differentiated between a requirement of continuing residency and a requirement of prior residency of a given duration. Thus in Shapiro, supra, at 636, we stated: “The residence requirement and the one-year waiting-period requirement are distinct and independent prerequisites.” And in Memorial Hospital, supra, at 255, quoting Dunn, supra, at 342 n. 13, the Court explained that Shapiro and Dunn did not question “ ‘the validity of appropriately defined and uniformly applied bona fide residence requirements.’ ” 424 U.S. at 647.

Numerous lower federal and state courts have decided residency requirement issues. After the Supreme Court cases, some adopted the fundamental “right to travel” rationale, then applied the strict compelling state interest test to invalidate the requirements,8 and at least one federal court has applied the same reasoning but found the necessary compelling state interest.9 However, more [774]*774often, to uphold statutory residency requirements for firemen and policemen, courts have found that they do not penalize the fundamental right to travel,10 and hence, need not be justified by a compelling state interest, but merely have a rational basis. See Andre v. Board of Trustees of Village of Maywood,

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Spradling v. Hutchinson
253 S.E.2d 371 (West Virginia Supreme Court, 1979)

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Bluebook (online)
253 S.E.2d 371, 162 W. Va. 768, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spradling-v-hutchinson-wva-1979.