State Ex Rel. Mulhern v. McHenry

326 A.2d 132, 31 Conn. Super. Ct. 172, 31 Conn. Supp. 172, 1974 Conn. Super. LEXIS 247
CourtConnecticut Superior Court
DecidedJune 19, 1974
DocketFile 137473
StatusPublished
Cited by4 cases

This text of 326 A.2d 132 (State Ex Rel. Mulhern v. McHenry) is published on Counsel Stack Legal Research, covering Connecticut Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Ex Rel. Mulhern v. McHenry, 326 A.2d 132, 31 Conn. Super. Ct. 172, 31 Conn. Supp. 172, 1974 Conn. Super. LEXIS 247 (Colo. Ct. App. 1974).

Opinion

John F. Shea, Jr., J.

This is an action in the nature of quo warranto to determine title to the office of chief of police of the town of Hamden. The action was originally instituted, on behalf of Hugh Mulhern, requiring Malcolm McHenry and officials of the town of Hamden to show by what right McHenry claimed to hold the office of chief of police. A counterclaim and cross complaint, also in the nature of quo warranto, was filed by representatives of the town, seeking to determine who rightfully holds the office of chief of police, Mulhern or McHenry. By agreement of the parties, the issues are to he resolved on the counterclaim and cross complaint.

Hugh Mulhern was appointed chief of police of Hamden in September, 1967. He continued in that office, without question, until December 27,1973. On that date, the retirement board of the town of Ham-den purported to order his retirement, effective January 1, 1974. On the same date, a vacancy pur *174 portedly existing in the office as of January 1, 1974, the then mayor of Hamden, William Adams, appointed Malcolm McHenry to the office of chief of police as of January 1, 1974.

On November 3, 1964, pursuant to chapter 99 of the General Statutes, the town of Hamden adopted a municipal charter, effective January 1, 1966. Section 17-7 of the charter provided for the continuation of the Hamden Employees Betirement Act, which had been adopted on May 8, 1962. The act was amended in 1969. Under its provisions, members of the police and fire departments are defined as “Guardian Employees.” The act provides that the “normal retirement date” of such an employee shall be “the first day of the calendar month next following the 60th anniversary of his birth, or the completion of 25 years of credited service, whichever is earlier.”

On December 27, 1973, Mulhern had twenty-eight years of credited service and was fifty-six years of age. The retirement board involuntarily retired Mulhern under the purported authority of § 4 (1) (a) of the Employees Betirement Act, which provides, in part, as follows: “A member shall be retired from service on a normal retirement .allowance upon reaching his normal retirement date. However, with the approval of the Board, a member may defer his retirement and remain in service after his normal retirement date provided, however, that in no event shall retirement be deferred beyond age 65, in the case of a guardian employee, or age 70 in the case of a service employee.”

As of the date the retirement board acted, Mulhern had made no formal request for a deferment although he had completed twenty-five years of service some three years earlier. Testimony at the trial indicated that the custom followed was not to *175 require a request for deferment unless the employee had reached sixty years of age. The basis for granting a deferment was the ability to pass a physical examination. There was no other guideline. After age sixty, guardian employees were required to take physical examinations each year, to extend their deferments to age sixty-five.

Prior to the retirement of Mulhern on December 27, 1973, no guardian employee had ever been involuntarily retired on the basis of years of service alone. On December 27, 1973, there were approximately twenty other guardian employees who had completed twenty-five years of service. This group included many of the top supervisory officers of the police and fire departments. Mulhern was the only one who was involuntarily retired by the board. As evidence of recognition of the custom that formal requests for deferment were not received until the employee reached age sixty, the motion passed by the retirement board in retiring Mulhern contained the following language: “. . . it is the sense of this Board that no deferment of normal retirement date be approved for said Chief Mulhern, and that any deferment assumed to previously have been approved should be terminated.”

Counsel for Mulhern argue that the action of the board in involuntarily retiring him amounts to an invidious discrimination in violation of his rights under the equal protection clause of the fourteenth amendment to the constitution of the United States. It is argued that Mulhern was singled out, as a member of an ordained class of employees with over twenty-five years of service, for selective and discriminatory treatment. It is not contested that Mulhern’s years of service provided the sole basis of the board’s action in ordering his retirement. No other reason was given.

*176 The intent of the equal protection clause is to secure every person within the state’s jurisdiction against intentional and arbitrary discrimination, whether occasioned by the express terms of a statute or by its improper execution. “An actual discrimination arising from the method of administering a law is as potent in creating a denial of equality of rights as a discrimination made by law.” 16 Am. Jur. 2d 929, Constitutional Law, § 540.

The basic principle requiring that equal protection of the laws extends to the application of the law was enunciated long ago in Yick Wo v. Hopkins, 118 U.S. 356, 373: “Though the law itself be fair on its face and impartial in appearance, yet, if it is applied and administered by public authority with an evil eye and an unequal hand, so as practically to make unjust and illegal discriminations between persons in similar circumstances, material to their rights, the denial of equal justice is still within the prohibition of the Constitution.”

The necessity of requiring that government officials exercise their powers so as not to discriminate was set forth in Railway Express Agency, Inc. v. New York, 336 U.S. 106, 112: “Conversely, nothing opens the door to arbitrary action so effectively as to allow those officials to pick and choose only a few to whom they will apply legislation and thus to escape the political retribution that might be visited upon them if larger numbers were affected. Courts can take no- better measure to assure that laws will be just than to require that laws be equal in operation.”

In ,a situation similar to the one at hand, it has been held that compulsory retirement of municipal civil service employees can be accomplished only by a general, nondiscriminatory ordinance which operates uniformly and equally upon all members of *177 the class created by the ordinance. Commonwealth ex rel. Siani v. Wilkes-Barre, 164 Pa. Super. 529; see Boyle v. Philadelphia, 338 Pa. 129.

Counsel for McHenry correctly argue, however, that the unlawful administration of a statute fair on its face, resulting in its unequal application to those who are entitled to be treated alike, is not a denial of equal protection unless there is shown to be present an element of “intentional or purposeful discrimination.” See Snowden v. Hughes, 321 U.S. 1, 7.

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Bluebook (online)
326 A.2d 132, 31 Conn. Super. Ct. 172, 31 Conn. Supp. 172, 1974 Conn. Super. LEXIS 247, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-mulhern-v-mchenry-connsuperct-1974.