Thomas Ogden v. Wa State Criminal Justice Training Commision

CourtCourt of Appeals of Washington
DecidedMarch 10, 2014
Docket69662-9
StatusUnpublished

This text of Thomas Ogden v. Wa State Criminal Justice Training Commision (Thomas Ogden v. Wa State Criminal Justice Training Commision) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thomas Ogden v. Wa State Criminal Justice Training Commision, (Wash. Ct. App. 2014).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

In the Matter of the Certification of No. 69662-9-1 THOMAS J. OGDEN, DIVISION ONE as f>0 — ^jc: Appellant. UNPUBLISHED OPI N£o

>ttm WASHINGTON STATE CRIMINAL JUSTICE TRAINING COMMISSION, FILED: March 10, 201& §2 Respondent.

Appelwick, J. — Ogden appeals the Criminal Justice Training Commission's

revocation of his peace officer certification and seeks to vacate the default order

entered against him. He argues that once he voluntarily surrendered his certification he

was no longer subject to the Commission's jurisdiction. He further contends that his

hearing date was improperly set and that good cause exists to vacate the default order.

We affirm.

FACTS

The Washington State Criminal Justice Training Commission (Commission)

provides programs and standards for the training of criminal justice personnel. RCW

43.101.020. Its powers include the ability to certify peace officers and revoke such

certification. RCW 43.101.095(3).

On February 8, 2008, the Commission granted Thomas Ogden peace officer

certification. Ogden was a Tacoma police officer until March 23, 2010, when he was

discharged for making false or misleading statements during an internal investigation. IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

In the Matter of the Certification of No. 69662-9-1 THOMAS J. OGDEN, DIVISION ONE Appellant. UNPUBLISHED OPINION

WASHINGTON STATE CRIMINAL JUSTICE TRAINING COMMISSION, FILED: Respondent.

Appelwick, J. — Ogden appeals the Criminal Justice Training Commission's

revocation of his peace officer certification and seeks to vacate the default order

entered against him. He argues that once he voluntarily surrendered his certification he

was no longer subject to the Commission's jurisdiction. He further contends that his

hearing date was improperly set and that good cause exists to vacate the default order.

The Washington State Criminal Justice Training Commission (Commission)

provides programs and standards for the training of criminal justice personnel. RCW

43.101.020. Its powers include the ability to certify peace officers and revoke such

On February 8, 2008, the Commission granted Thomas Ogden peace officer

certification. Ogden was a Tacoma police officer until March 23, 2010, when he was

discharged for making false or misleading statements during an internal investigation. No. 69662-9-1/2

The Commission subsequently sought to revoke Ogden's peace officer

certification. Ogden requested a revocation hearing. His counsel appeared at an initial

prehearing conference, during which the parties set October 19, 2011 as Ogden's

hearing date. The parties later agreed to extend the hearing date to November 4, 2011.

On August 26, 2011, Ogden attempted to voluntarily surrender his peace officer

certification. The Commission declined to accept the surrender and denied Ogden's

motion to dismiss the proceedings against him. Ogden also moved for a writ of

prohibition in King County Superior Court, seeking to arrest the proceedings for lack of

jurisdiction. The court denied his writ.

On October 20, 2011, the parties held another prehearing conference. Ogden's

counsel again represented him. During the conference, the parties agreed to move the

hearing date to December 19-20, 2011. After the conference, the parties discovered

that an important witness had a conflict on those dates and agreed to reschedule for

December 15-16, 2011.

Shortly before the hearing, Ogden realized that his attorney mistakenly told him

the hearing was December 19-20. Ogden had moved a business trip from December

19 to December 15 to avoid what he thought would be a conflict. Ogden's attorney

informed the Commission about the mix-up and Ogden's expected absence. He noted

that counsel would represent Ogden on the first day of the hearing, but Ogden would be

present on the second. Counsel took full responsibility for the error. No. 69662-9-1/3

Ogden also provided a declaration explaining the conflict. He stated that it was

too late to change his travel plans and that his tickets were nonrefundable. Attached

was a copy of his trip itinerary that showed he had a flight reservation for December 15,

but had not yet purchased the ticket. The hearing panel's presiding member replied that

he expected Ogden to appear in person at the hearing as required by WAC 139-06-

100(1).

The hearing took place on December 15, as scheduled. Ogden was not present,

but was represented by counsel. The panel found Ogden in default for failing to appear

in person.

Ogden subsequently moved to vacate the default order entered against him. The

Commission denied his motion. Ogden then petitioned King County Superior Court to

vacate the order of default and dismiss the order revoking his peace officer certification.

He argued that the Commission lacked jurisdiction over his hearing, his hearing date

was improperly set, and good cause existed for the court to vacate the default order.

The court affirmed

Ogden appeals the superior court's ruling

DISCUSSION

On appeal, Ogden raises the same three arguments as below. He first contends

that the Commission lacked jurisdiction over his revocation hearing after he voluntarily

surrendered his certification. He further contests his hearing date, arguing that the

presiding panel member scheduled the hearing without the full panel's agreement and

that Ogden did not agree to extend the date to December. Finally, Ogden argues that No. 69662-9-1/4

good cause existed to vacate the default order, because he understandably relied on

his attorney's misinformation and did everything he could to comply with the hearing

requirements.

I. Jurisdiction Over Revocation Hearing

Ogden maintains that, once he surrendered his certification, the Commission's

limited jurisdiction no longer extended to him. We review de novo the decision to grant

or deny a motion to vacate a default order for lack of jurisdiction. Brown v. Garrett, 175

Wn. App. 357, 366, 306 P.3d 1014 (2013).

A. Collateral Estoppel

As a threshold matter, the Commission counters that Ogden is collaterally

estopped from challenging jurisdiction, because the superior court already decided the

issue when it denied his petition for a writ of prohibition. Collateral estoppel bars

relitigation of a particular issue or fact previously determined by a valid and final

judgment. State v. Brvant. 146 Wn.2d 90, 98, 42 P.3d 1278 (2002). Generally, the

doctrine requires that:

"(1) the issue decided in the prior adjudication must be identical with the one presented in the second; (2) the prior adjudication must have ended in a final judgment on the merits; (3) the party against whom the plea of collateral estoppel is asserted must have been a party or in privity with a party to the prior litigation; and (4) application of doctrine must not work an injustice."

ig\ at 98-99 (internal quote marks omitted) (quoting State v. Williams, 132 Wn.2d 248,

254, 937P.2d 1052(1997)).

Here, the issue decided in the prior adjudication is identical to the one Ogden

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