Todd v. Geno

CourtVermont Superior Court
DecidedSeptember 27, 2013
Docket75
StatusPublished

This text of Todd v. Geno (Todd v. Geno) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Todd v. Geno, (Vt. Ct. App. 2013).

Opinion

Todd v. Geno et. al., No. 75-1-13 Rdcv (Toor, J., Sept. 27, 2013). [The text of this Vermont trial court opinion is unofficial. It has been reformatted from the original. The accuracy of the text and the accompanying data included in the Vermont trial court opinion database is not guaranteed.]

VERMONT SUPERIOR COURT RUTLAND UNIT CIVIL DIVISION

│ ANDREW N. TODD │ Plaintiff │ │ v. │ Docket No. 75-1-13 Rncv │ KEVIN E. GENO, et al., │ Defendants │ │

RULING ON PENDING MOTIONS.

Plaintiff Todd sues his former employer, the City of Rutland, and various other City

employees in connection with his past employment as a Rutland police officer. His initial

complaint alleges constructive termination, illegal retaliation for making complaints against his

superiors, denials of equal protection and due process, conspiracy, violation of the Vermont Fair

Employment Practices Act, and intentional infliction of emotional distress. In response to

motions to dismiss, Todd has moved to amend the complaint to delete certain claims and add

others. The proposed amended complaint asserts only three causes of action: “Violation of

Vermont’s Hate-Motivated Crime Statute,” violation of the Vermont Fair Employment Practices

Act, and “Conspiracy/Concerted Action.” It also proposes to add two new defendants.

The undersigned was recently appointed to handle the case after all the judges sitting in

Rutland County recused themselves, presumably due to their experience dealing with some or all

of the parties on a regular basis in the court system. Defendants Tremblay and the City have filed

motions to dismiss, and defendants the City, Geno, Tucker, Jensen and Baker have filed

oppositions to the amendment of the complaint. The court will address each motion in turn. I. Motion to Amend the Complaint

Because this case is at an early stage of the proceedings, and because no objections to the

motion to amend were filed within the time allowed by the rules, the court will grant the motion

to amend the complaint. However, the court will address below the substantive issues raised in

the objections to amendment, and treat them as requests for dismissal of the amended claims.1

II. The City’s Motion to Dismiss Based Upon 24 V.S.A. §§ 901(a) and 901a

The first motion filed by the City actually seeks dismissal of the claims not against the

City but against Geno, Tucker, Baker and Jensen on the ground that those claims must proceed

only against the City. Specifically, the City argues that because the claims against these

defendants all relate to actions within the scope of their employment, the City is the only proper

defendant. 24 V.S.A. §§ 901(a) and 901a.

Todd responds by pointing to the statutory exception for acts that are willful, intentional,

or outside the scope of employment, and argues that until those issues are resolved the claims

against the individual defendants are proper. 24 V.S.A. § 901a(e). A straightforward reading of

the statute supports Todd’s argument. The City cites legislative history for the proposition that

once the municipality provides a defense for the individuals, they must be removed from the

case. However, the statute does not support that reading for cases such as this, in which it is

alleged that the individuals acted outside the scope of their employment. In that situation, the

statute refers to a court dismissing such parties after making a determination that the actions

1 Todd has attached numerous documents to his reply memorandum in support of the motion to amend (Although he calls the memo something else, it is in fact a reply. See V.R.C. P. 78(b)(1)(setting forth order of filings as motions, responses, and replies)). He also adds facts in his memorandum that are not in the complaint. The court will not consider any of these new alleged facts or documents, as none are contained in the proposed Amended Complaint.

2 were not “willful, intentional, or outside the scope of the employee’s authority.” Id. §

901a(d)(2). The amended complaint survives the motion.2

The City also urges that the VFEPA claim must be dismissed against the individuals

because they are not the “employer.” However logical that may seem on its face, our Supreme

Court has held that individual employees are subject to liability under the statute. Payne v. U.S.

Airways, Inc., 2009 VT 90, ¶ 21, 186 Vt. 458 (“[[T]he VFEPA allows for suits against

employees as individuals.”).

III. The Motion to Dismiss the City and to Strike

The City raises a number of issues in its motion to be dismissed from the case. Each will

be discussed in turn.

A. Conclusory Allegations

The City first raises a general argument seeking to strike or dismiss what it describes as

conclusory allegations in the complaint. However, the amended complaint provides greater

specificity to the claims that remain. Many remain extremely conclusory, it is true. However,

despite dissents urging stricter standards – see, Bock v. Gold, 2008 VT 81, ¶ 15, 184 Vt. 575

(Skoglund, J. dissenting)(“In reviewing the sufficiency of a complaint, this Court . . . need

not accept conclusory allegations or legal conclusions masquerading as factual conclusions.”)

and Colby v. Umbrella, Inc., 2008 VT 20, ¶ 20, 184 Vt.1 (Burgess, J., dissenting)(urging that

plaintiffs be required to plead more than “labels and conclusions, and a formulaic recitation of

the elements of a cause of action”)(citation omitted) – Vermont has a “low threshold for

withstanding a 12(b)(6) motion to dismiss.” Colby, 2008 VT 20, ¶ 8. Thus, our Supreme Court

has so far not adhered to the stricter pleading standards applicable in some other jurisdictions

2 If, on summary judgment, it is shown that the acts were within the scope of employment and not “willful” or “intentional” under the statute, the individual defendants could then properly be removed as parties.

3 (such as in the federal cases cited by the City). Here, a “complaint need not give a specific and

detailed statement of the facts constituting the cause of action.” Murray v. City of Burlington,

2012 VT 11,¶ 13, 191 Vt. 597 (citation omitted).

The Vermont Supreme Court cases cited by the City do not say otherwise. One relates to

what must be proffered in response to a summary judgment motion, not a motion to dismiss.

White v. Quechee Lakes Landowners’ Ass’n, Inc., 170 Vt. 25, 28 (1999). Nor does the case the

City cites for the proposition that allegations of conspiracy require a heightened pleading

standard say that. Instead, it says that “[n]o court will accept conclusory allegations of a

conspiracy, without more, as sufficient to establish personal jurisdiction” over an out-of-state

defendant. Schwartz v. Frankenhoff, 169 Vt. 287, 295 (1999).3 Thus, with the exception of

matters discussed below, the court finds the amended complaint to be sufficient.

B. Count I: Hate-Motivated Crime

The City argues that the “hate crime” cause of action fails against it. Although conceding

that the criminal statute expressly creates a private right of action, 13 V.S.A. § 1457, the City

argues that a specific intent crime such as this cannot be imputed to a municipality. This is

clearly a specific intent crime, requiring that a defendant’s conduct be “maliciously motivated

by” a discriminatory purpose. Id. § 1455.

Employee actions can, under certain circumstances, be imputed to their corporate

employers.

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