Derek Davis v. Shelby County Sheriff's Department

Summary

The Tennessee Supreme Court reviewed the termination of a Shelby County Sheriff's Department patrol officer for violating the department's drug-free workplace program. The court held that the Court of Appeals applied the wrong standard of review, that the positive urine test was admissible evidence, and that the Civil Service Merit Board's termination decision was not arbitrary or capricious and was supported by substantial and material evidence. The court reversed the Court of Appeals and reinstated the trial court's judgment.

Holdings

1. Judicial review of a county civil service board decision affecting the employment status of a civil service employee is governed by the judicial-review standards of the Uniform Administrative Procedures Act under Tennessee Code Annotated section 4-5-322, not common-law writ-of-certiorari review.
2. The positive urine specimen test result was admissible before the Civil Service Merit Board.
3. The Board's decision to terminate Davis was neither arbitrary nor capricious and was supported by substantial and material evidence.

Questions Presented

1. Whether judicial review of the Shelby County Civil Service Merit Board's employment-termination decision is governed by common-law writ-of-certiorari standards or the Uniform Administrative Procedures Act standards in Tennessee Code Annotated section 4-5-322.
2. Whether the positive urine specimen test result was admissible evidence before the Civil Service Merit Board despite Davis's challenges to the specimen's identification and chain of custody.
3. Whether the Board's decision to terminate Davis was arbitrary or capricious or unsupported by substantial and material evidence.

Disposition

reversed