State ex rel. Madden v. Anderson

2024 Ohio 5596
CourtOhio Court of Appeals
DecidedNovember 25, 2024
Docket30086
StatusPublished

This text of 2024 Ohio 5596 (State ex rel. Madden v. Anderson) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State ex rel. Madden v. Anderson, 2024 Ohio 5596 (Ohio Ct. App. 2024).

Opinion

[Cite as State ex rel. Madden v. Anderson, 2024-Ohio-5596.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MONTGOMERY COUNTY

STATE OF OHIO, EX RELATIONE: C.A. No. 30086 GLENA MADDEN

Relator

v. DECISION AND FINAL JUDGMENT ENTRY PETER SEXTON AND MUNICIPALITY OF NEW LEBANON

Respondents ______________________________________________________________________ PER CURIAM:

{¶ 1} Glena Madden (“Madden”), the former municipal manager of the

Municipality of New Lebanon (“New Lebanon” or “the village”), seeks a writ of quo

warranto to oust Robert L. Anderson, II (“Anderson”), New Lebanon’s acting municipal

manager.1 Upon consideration of the evidence submitted and the briefs of the parties, we

will deny the writ.

1 Anderson and New Lebanon are the named respondents in the complaint. For

the reasons set forth in Section II.C. of this decision, Peter Sexton is substituted as a party for respondent Anderson. -2-

I. Charter Government in New Lebanon

{¶ 2} New Lebanon is a village in Montgomery County, Ohio. See R.C. 703.01(A)

(classifying municipalities with a population of less than 5,000). Although most villages in

Ohio are governed by a statutory form of government, New Lebanon has a charter form

of government. See Ohio Municipal League, Charter & Statutory Municipalities,

http://www.omlohio.org/DocumentCenter/View/116/Cities-and-Villages-with-Charters-

PDF (accessed Nov. 14, 2024).

{¶ 3} New Lebanon’s charter provides that legislative power in the village is

vested in a mayor and six council members, the collective body of which constitutes the

village council. See New Lebanon Charter § 2.01. The mayor is a voting member of the

council who presides at all meetings. Id. at § 2.04. The council elects a vice mayor from

among its members to serve as acting mayor if the mayor is absent from the village or

unable to perform his duties. Id. at § 2.04, 2.05. The council legislates by resolution or

ordinance. Id. at § 2.10. The charter provides that: “An affirmative vote of a majority of

Council shall be required for the enactment of every ordinance or resolution, unless a

larger number be required by the provisions of this Charter.” Id.

{¶ 4} New Lebanon’s charter also specifies that it has adopted the “Manager

Form of Government.” Id. at § 1.03. The “manager plan” of municipal government is

generally found in cities. See R.C. 705.51 (referring to “[t]he form of government provided

in sections 705.51 to 705.60, inclusive, of the Revised Code” as the “city manager plan”).

In cities with a manager plan of government, the council appoints a manager who serves

as the administrative head of the municipal government. R.C. 705.51(C); R.C. 705.58. -3-

The manager works under the direction and supervision of the council and holds office at

the pleasure of the council. R.C. 705.58.

{¶ 5} So too, in New Lebanon, the village council appoints a “Municipal Manager.”

New Lebanon Charter § 4.01. The municipal manager is the chief executive and

administrative officer of the village. Id. at § 4.02. The municipal manager is responsible to

the council for the administrative affairs of the village. Id. Under the charter, the

administrative officers of the village report directly to the municipal manager. Id. at § 4.05.

For example, the director of finance and records serves as clerk of council and performs

their duties under the general direction of the municipal manager. New Lebanon

Ordinance 30.01(B)(4). Further, the charter provides that “[n]either Council, nor its

committees, shall in any manner take part in the discipline of, nor give orders to, any

subordinates and employees in the administrative service of the Municipality responsible

to the Manager, but must deal directly with the Manager.” Charter § 2.18.

{¶ 6} Having briefly outlined the form of New Lebanon’s government, we proceed

to the relevant facts of the case.

II. Factual Background {¶ 7} Madden began serving as New Lebanon’s municipal manager in February

2019. On October 3, 2023, the village council reappointed Madden as municipal manager.

New Lebanon Resolution No. 2023-15 specified that:

Madden is hereby currently the appointed Municipal Manager of the

Municipality of New Lebanon and will continue to be appointed for an

additional five year[s] in accordance with terms and conditions of the

Employment Agreement negotiated by the Mayor, Council, and Manager

and commencing upon signing by the Manger and Mayor. -4-

{¶ 8} Notwithstanding the anticipated five-year term of employment, Madden’s

employment agreement with New Lebanon made clear that she served at the pleasure of

the village council. The agreement allowed the council to remove Madden from office

before the expiration of her term. However, the agreement required an affirmative vote of

five councilmembers to remove Madden from office – a supermajority.

{¶ 9} New Lebanon elected new councilmembers in the November 2023 general

election, including Mayor David Nickerson. On February 20, 2024, at a public meeting,

the village council undertook three legislative actions. First, the council enacted

Resolution No. 2024-4 to engage a law firm to conduct an internal investigation into the

administrative, financial, and legal affairs of the village. Second, the council enacted

Resolution No. 2024-5 placing Madden on administrative leave during that investigation.

Third, the council enacted Resolution No. 2024-6 authorizing Mayor Nickerson to:

engage, negotiate, execute a contract, and subsequently appoint a qualified

candidate as Acting Village Manager to fulfill the duties and responsibilities

of the Village Manager, as set forth in the New Lebanon Charter, during the

pendency of the Village’s internal investigation.

Each of the resolutions (collectively referred to as the “February 20 resolutions”) was

approved by a bare majority of the council – four votes in the affirmative, three in the

negative. Mayor Nickerson and Councilmember Nicole Adkins, the vice mayor, voted in

the affirmative with respect to each resolution.

{¶ 10} Resolutions of the village council must be authenticated by the signature of

the mayor and the director of finance and records, i.e., the clerk of council. New Lebanon

Charter § 2.14. During the February 20, 2024 meeting, the council placed the clerk on -5-

administrative leave. See Resolution No. 2024-5. Because of the clerk’s placement on

administrative leave or the clerk’s unwillingness to perform his duties (it is unclear), Mayor

Nickerson appointed Councilmember Adkins as acting clerk at the February 20 meeting.

Adkins’s signature appears on each of the February 20 resolutions as the “Vice

Mayor/Acting Clerk of Council.”

{¶ 11} After the village council enacted the February 20 resolutions, Mayor

Nickerson negotiated and executed a contract with Anderson to provide “independent

consulting services” to the village. The contract includes a statement of work which

provides that Anderson will perform:

The ordinary and customary duties and responsibilities of a village manager

including but not limited to, all duties assigned that are legal and within the

scope of employment as provided in Article IV of the Charter of the Village

of New Lebanon, any applicable ordinance, or as determined by the Village

Council for the efficient management of the Village of New Lebanon.

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