Walton v. Montgomery County Welfare Department

430 N.E.2d 930, 69 Ohio St. 2d 58, 23 Ohio Op. 3d 93, 1982 Ohio LEXIS 536
CourtOhio Supreme Court
DecidedJanuary 20, 1982
DocketNo. 81-355
StatusPublished
Cited by28 cases

This text of 430 N.E.2d 930 (Walton v. Montgomery County Welfare Department) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Walton v. Montgomery County Welfare Department, 430 N.E.2d 930, 69 Ohio St. 2d 58, 23 Ohio Op. 3d 93, 1982 Ohio LEXIS 536 (Ohio 1982).

Opinion

William B. Brown, J.

The first question presented is whether a probationary employee who has completed 60 days or one-half of her probationary period, whichever is greater, may be removed for unsatisfactory service without right of appeal to the State Personnel Board of Review. For the following reasons, we hold that no right of appeal is provided to such employee by statute or by Section 10, Article XV of the Ohio Constitution.

Since 1913, Ohio has provided for a probationary period for civil service employees. The requirement of a period of probationary service has been held to be part of a valid statutory scheme implementing Section 10, Article XV of the Ohio Constitution. State, ex rel. Clements, v. Babb (1948), 150 Ohio St. 359, 368-369. Specifically, in Babb, this court held that the requirement of the Ohio Constitution that appointments and promotions be ascertained by competitive examination “as far as practicable” leaves room for the possibility that examination might not be the sole test of merit and fitness. For that reason a probationary period might be imposed to aid in determining fitness. Id. Successful completion of the prescribed probationary period is required before appointment to a civil service position is made final. State, ex rel. Artman, v. McDonough (1936), 132 Ohio St. 47, 49.

Since the probationary period is for the benefit of the appointing authority to aid in the determination of merit and fitness for civil service employment, State, ex rel. Kelley, v. Hill (1950), 88 Ohio App. 219, 221, the General Assembly historically has provided for a degree of leeway in the dismissal of probationary employees. State, ex rel. Stine, v. Atkinson (1941), 138 Ohio St. 217, 219. As originally enacted, G. C. [60]*60486-13 (predecessor to R. C. 124.27)1 provided that leeway at the end of the probationary period:

“ * * * At the end of the probationary period the appointing officer shall transmit to the civil service commission a record of the employe’s service, and if such service is unsatisfactory, the employe may with the approval of the commission, be removed or reduced without restriction; but dismissal or reduction may be made during such period as provided in section 17 hereof.” (103 Ohio Laws 698.)

Although this statute appeared to provide appeal rights for employees dismissed during the probationary period, the reported cases uniformly addressed the issue of appeal from [61]*61removal at the end of the probationary period. The distinction serves to point out a historical dichotomy in legislative policy regarding probationary employees. This policy affords a probationary employee the criteria for his removal and the full appeal rights of a tenured employee at the earlier stages of public employment. Thus, probationary employees may receive a fair trial on the job and have “an opportunity to demonstrate their ability and competence in their job positions.” Hill v. Gatz (1979), 63 Ohio App. 2d 170, 173-174.2 On the other hand, at the later stages of probationary employment, the interest of the appointing authority in maintaining a satisfactory and competent work force comes into play, and discretionary removal is allowed.

This historical legislative balancing of interests through a two-stage probationary process has been carried over into the present R. C. 124.27, which provides: “ * * * if the service of the probationary employee is unsatisfactory, he may be removed or reduced at any time during his probationary period after completion of sixty days or one-half of his probationary period, whichever is greater. If the appointing authority’s decision is to remove the appointee, his communication to the director shall indicate the reason for such decision. Dismissal or reduction may be made under provisions of section 124.34 of the Revised Code during the first sixty days or first half of the probationary period, whichever is greater.” This section [62]*62continues an unbroken legislative policy of nearly 70 years that no appeal shall be provided from a removal other than at a specified stage in the probationary period.

Appellee contends that affirmance is compelled by State, ex rel. Kendrick, v. Masheter (1964), 176 Ohio St. 232. In Masheter this court held that R. C. 143.0123 (predecessor to R. C. 124.03 [B]) provided jurisdiction to the State Personnel Board of Review to hear appeals by classified civil service employees from layoff decisions of appointing authorities. This argument fails on two grounds.

First, the statutory scheme in effect when Masheter, supra, was decided did not include any specific language concerning appeal from layoffs. Thus, we turned to the general provisions of R. C. 143.012 to determine whether such an appeal was intended by the General Assembly. Given the general requirement that an appeal be provided, and noting the absence of any specific provision denying an appeal, we concluded that such an appeal was contemplated. That conclusion was necessary in order to accomplish the legislative plan of R. C. Chapter 143 and to avoid an absurd result. Id., at page 234.

No such difficulty arises here. The General Assembly specifically provided in R. C. 124.27 a two-tiered scheme for probationary removal and appeal. These specific provisions control over the more general language of R. C. 124.03(B). R. C. 1.51. This case is distinguishable, then, from Masheter in that R. C. Chapter 143 provided no specific provision concerning appeal from layoff, whereas R. C. Chapter 124 does specifically address appeal from probationary removal. There is no necessity in the case sub judice to revert to the general statute to effectuate the legislative scheme.

Secondly, construction of R. C. 124.27 so as to provide an appeal from second-half probationary removals would result in [63]*63absurd consequences clearly sought to be avoided by the General Assembly. The granting of such an appeal, without tying it into the procedural steps required by R. C. 124.34, would create different statutes of limitation for appeal, different records for review, and varying appeal rights from decisions of the State Personnel Board of Review for the two categories of probationary removal. There is no support in R. C. Chapter 124 for this anomalous situation and we decline to impose it through an act of judicial legislation.4

Furthermore, the Masheter decision placed reliance on the administrative interpretation of the statute in question. Id., at page 235. Accordingly, we note that Ohio Adm. Code 124-1-06. is in accord with our view of R. C. 124.27.5

Our decision here does not leave second-half probationary employees subject to the unfettered whim and caprice of appointing authorities. Abuse of the discretion granted to those having the power of removal may be redressed pursuant to R. C. 124.56. However, any further right of appeal by second-half probationary employees must await legislative action.

The second question presented is whether the due process clause of the Fourteenth Amendment to the United States Constitution compels Ohio to accord a hearing to a civil service employee removed during the second half of her probationary period. We conclude that the Constitution does not so require.

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Bluebook (online)
430 N.E.2d 930, 69 Ohio St. 2d 58, 23 Ohio Op. 3d 93, 1982 Ohio LEXIS 536, Counsel Stack Legal Research, https://law.counselstack.com/opinion/walton-v-montgomery-county-welfare-department-ohio-1982.