UNIFIED GOVERNMENT OF ATHENS-CLARKE COUNTY v. BRYAN JONES

CourtCourt of Appeals of Georgia
DecidedMarch 13, 2025
DocketA24A1309
StatusPublished

This text of UNIFIED GOVERNMENT OF ATHENS-CLARKE COUNTY v. BRYAN JONES (UNIFIED GOVERNMENT OF ATHENS-CLARKE COUNTY v. BRYAN JONES) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
UNIFIED GOVERNMENT OF ATHENS-CLARKE COUNTY v. BRYAN JONES, (Ga. Ct. App. 2025).

Opinion

FIFTH DIVISION MERCIER, C. J., MCFADDEN, P. J., and RICKMAN, P. J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

March 13, 2025

In the Court of Appeals of Georgia A24A1309. UNIFIED GOVERNMENT OF ATHENS-CLARKE COUNTY et al. v. JONES.

MERCIER, Chief Judge.

Corporal Bryan Jones was fired from his job with the Athens-Clarke County

Sheriff’s Department and, following an administrative appeal, a hearing officer

affirmed Jones’s termination. Jones then filed a writ of certiorari to the superior court,

seeking review of the administrative decision. The trial court granted the writ and

ordered that Jones be reinstated. The Unified Government of Athens-Clarke County

and William C. Berryman, Jr., in his official capacity as Personnel Hearing Officer,

(collectively “the County”) appeal, contending that the superior court erred in

reversing the decision of the hearing officer and by ordering Jones’s reinstatement.

For the reasons that follow, we agree and reverse. 1. The County contends that the superior court erred by applying the wrong

standard of review in its decision to reinstate Jones.

“The appropriate standard of review to be applied to issues of fact on writ of

certiorari to the superior court is whether the decision below was supported by any

evidence.” DeKalb County v. Bull, 295 Ga. App. 551, 552 (1) (672 SE2d 500) (2009)

(citation, footnote and punctuation omitted; emphasis in original). On appeal, “our

duty is not to review whether the record supports the superior court’s decision but

whether the record supports the initial decision of the local governing body or

administrative agency.” Id. (citation and punctuation omitted). The factfinder in the

initial proceeding is charged with weighing the evidence and judging witness

credibility. See id. On review, therefore,

the superior court and this Court must view the evidence in the light most favorable to the factfinder’s decision and must affirm the decision if there is any evidence to support it, even when the party challenging the factfinder’s conclusions presented evidence during the initial proceedings that conflicted with those conclusions.

Id. While the superior court cited the correct standard of review in its order, it failed

to follow the standard.

2 Viewed in the light most favorable to the hearing officer’s decision, the

transcript of the hearing shows the following relevant facts. DeKalb County, 295 Ga.

App. at 553 (1). On February 2, 2022, Rakeim Hillsman, an inmate at the Clarke

County jail, was in the intake holding cell “beating on the door complaining that he

needed to see the nurse.” Hillsman had not received medical treatment for

approximately three and a half hours. Jones went to calm him down and opened the

door to the cell. Hillsman informed Jones that he could not sit on the hard concrete

benches because he was injured. Jones responded that he could not move Hillsman out

of the cell until Hillsman was processed and “sent to the back,” where Hillsman

would have a mattress. Jones then closed the cell door, and Hillsman continued to yell.

Eventually, Jones and Corporal Palmer took Hillsman (who was handcuffed at

the time) to the court-side holding cell because it was farther away from the front area

where the officers were screening inmates. As they were walking, Jones told Hillsman

that he would have a softer place to sit. Hillsman stated that he had just had surgery,

explaining that he had “metal in [his] back and legs.” Significant surgical scars on the

Hillsman’s neck were also clearly visible.

3 Once they arrived at the second cell, Hillsman asked again if there was

somewhere softer for him to sit, and Jones told Hillsman that he could sit on the

concrete benches or the toilet. As Jones was closing the solid door to the cell,

Hillsman spat towards Jones, but the spit did not hit him. Jones then said: “Open this

door back up and get me the restraint chair, he just spit.” Jones did not seek approval

from a supervisor prior to ordering the restraint chair, and Hillsman was handcuffed

in a cell by himself with the solid cell door closed at the time.

Once a restraint chair was obtained, Jones yanked Hillsman’s shirt to get him

into the chair. The first chair was defective, and Hillsman was able to free his arms,

but his leg shackles were still intact. Jones walked into the cell to switch restraint

chairs, and Hillsman spat at Jones. While Hillsman was still in leg shackles in the first

restraint chair, Jones punched Hillsman in the face twice, and Hillsman fell over in the

chair. As several employees secured Hillsman in the second chair, Jones twisted

Hillsman’s head, causing Hillsman to cry out repeatedly.

After reviewing body camera video of the events, the sheriff terminated Jones.1

Specifically, Jones was fired for violating Clark County Sheriff’s Office standard

1 Hillsman had worked for the County for over eight years. 4 operating procedures regarding: use of a restraint chair; response to

resistance/aggression; and inefficiency, negligence and/or incompetence of duties.

The Notice of Intent to Terminate Employment also noted that Jones had seven past

violations of standard operating procedures. Jones appealed, and, following an

evidentiary hearing, a personnel hearing officer found that Jones failed to establish by

a preponderance of the evidence that (a) his termination was inconsistent with the

policies of the Athens-Clarke County Code of Ordinances or other applicable laws,

policies, practices, or procedures, or (b) the factual basis for his termination was not

true or correct or was substantially inaccurate. The hearing officer thus affirmed his

termination.

Jones filed a petition for writ of certiorari with the superior court. After

conducting a hearing, the superior court, using an order prepared by Jones’s counsel,

reversed the decision of the personnel hearing officer. Thereafter, we granted the

County’s application for discretionary appeal.

The Clarke County Sheriff’s office has established a departmental policy

regarding the proper use of a restraint chair, explaining that:

The restraint chair is only to be used as a restraint device for subjects who demonstrate an immediate and compelling intent to commit an act

5 of property damage or abuse, physical disruption and/or physical resistence to authority, and/or physical harm to themselves or others, or whose mental state or condition renders them or places others in danger of injury unless temporarily restrained.

The policy also prohibits the use of “the restraint chair as punishment or to restrain

a subject for acts of violence, disruption, or property damage previously committed

if the subject is demonstrating no intent of continuing such activity.” A separate

policy governing the response to resistance and aggression further provides:

Personnel will use only reasonable force to accomplish their legal objectives and apply de-escalation techniques when possible. Once the need for force is no longer present (because resistance ends and/or the possibility of violence is removed), the continued response to resistance/aggression cannot be justified.

Evidence presented at the hearing showed that when Jones first ordered use of

a restraint chair, Hillsman was by himself in a locked cell, wearing handcuffs and

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Related

DeKalb County v. Bull
672 S.E.2d 500 (Court of Appeals of Georgia, 2009)
Glass v. City of Atlanta
666 S.E.2d 406 (Court of Appeals of Georgia, 2008)

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