Patterson v. Linn

SABERS, Justice

(dissenting).

[¶ 15.] It is apparent that the plain language of SDCL 9-14-13 provides the May- or with the power to remove employees when it is deemed necessary. In that regard, this statute recognizes that employees appointed by the Mayor may be at-will. The statute, however, does not prevent a Mayor from hiring employees for specific terms.3 The statute recognizes a limit on the power to remove an employee by conditioning that power with the language “unless otherwise provided.” The language contained in SDCL 9-14-13 is in accord with the rule that South Dakota is an employment at-will state, with exceptions that can remove an employee from the at-will status. SDCL 60-4-4. See also Merritt v. Edson, 437 N.W.2d 528, 529 (S.D.1989) (holding that in the absence of a written contract or specified term of employment the employee is terminable at-will).

[¶ 16.] The majority opinion erroneously states that “to interpret the phrase ‘except as otherwise provided’ as meaning to permit a city to grant tenure to a city officer makes the statute self-contradictory and contravenes the pattern of municipal governance defined in our statutory scheme.” *471The majority opinion fails to appreciate the fact that Mayor chose to appoint Patterson to a one-year term. Mayor specified the one-year term and Council approved that appointment. Mayor, himself, decided to limit his power to terminate at-will. A city council cannot remove the at-will status, only Mayor can. The facts here also demonstrate that Patterson was appointed and serving under Mayor. The majority opinion states that, if Patterson’s interpretation of SDCL 9-14-13 is adopted, it “would entitle a common council effectively to annul the Legislature’s express grant of removal power and allow an outgoing regime to install officers for an incoming regime.” The majority opinion sets forth a parade of horribles that simply does not exist. This is not a situation where the outgoing officer made “midnight appointments” to preserve his legacy. The majority opinion is addressing an issue that is not there. The majority opinion is not beating a dead horse, it is beating a nonexistent one.

[¶ 17.] The majority opinion seizes on the language of SDCL 9-14-13 to determine that the Mayor hires at-will. Yet, it is clear that in South Dakota at-will employment is the norm, not the exception. SDCL 60-4-M. Why would the Legislature duplicate itself by reasserting the at-will statute in SDCL 9-14-13?

[¶ 18.] Instead, the Legislature has indicated with SDCL 9-14-13 that Mayor has the power to hire and fire any official, even if the person is not at-will, to protect the public when it is deemed necessary. The statute clearly indicates Mayor has the power to remove an employee when he is of “the opinion that the interests of the municipality demand.” The majority opinion relies upon Ruple, 328 N.W.2d at 859, and Finch, 443 N.W.2d at 632, to support its point. This reliance is misplaced. In these cases, we upheld the termination of both employees based on their at-will status. Significantly, neither case involved employees who were hired for a specified term and are therefore distinguishable.

[¶ 19.] The majority opinion mistakes the power to remove an employee to protect the municipality with a blanket rule that no official may be hired unless he or she is at-will. This is tantamount to hamstringing municipal governments. The protections afforded a contract or term employee are a legitimate bargaining tool for the municipality to attract experienced and competent personnel. SDCL 9-14-13 allows municipalities that power, but it also allows the Mayor to get rid of a person with expedience if a problem develops. Nonetheless, this quick action does not relieve the municipality from liability if the removal was without just cause. That determination can only be made at trial.

[¶ 20.] The Mayor hired Patterson for a one-year term and such hiring was approved by the City Council. The warrant of appointment was signed by Patterson and the Mayor. (See Attachment). The position taken by the City and supported by the majority would seem to constitute fraud if the parties were reversed. Patterson proved that Mayor relinquished his power to remove her without regard to liability. Therefore, summary judgment was inappropriate and I respectfully dissent.

[¶ 21.] AMUNDSON, Justice, joins this dissent.

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. As a practical matter, the Legislature could have reasonably contemplated that the inability to limit at-will status could compromise the ability to hire and retain competent and experienced personnel.