City of Memphis v. The Civil Service Commission, et al.

This administrative appeal arises out of the termination of Officer Lenora Armstead’s (Officer Armstead) employment with the Memphis Police Department (the Department). The City took this action as a result of a public altercation between Officer Armstead and another off-duty police
officer. It found that Officer Armstead had violated DR-104 Personal Conduct and terminated her employment because of this violation and other disciplinary proceedings previously brought against her. The Civil Service Commission of the City of Memphis (the Commission) reversed the City’s decision to terminate her employment because it found the action to be unreasonable. The City appealed to Shelby County Chancery Court, where the chancellor reversed the Commission’s decision, finding it to be arbitrary and capricious. We find that the City proved a violation of DR-104 but that the Commission’s decision was supported by substantial and material evidence. We reverse and remand.