City of Meridian, Mississippi v. Adam Meadors
222 So. 3d 1045
| Miss. Ct. App. | 2016Background
- Officer Adam Meadors (MPD since 2006) posted a public Facebook photo on duty (on a meal break) depicting two chimpanzees with a caption mocking “the mayor and the chief of police,” then removed it minutes later.
- MPD investigated; Meadors admitted he knew the post might offend some people and acknowledged local friends would assume he referred to Mayor Percy Bland and Chief James Lee.
- Chief Lee issued a notice of intent to terminate (Mayor Bland’s signature was not on the notice); Meadors was terminated on October 16, 2013, and appealed to the Meridian Civil Service Commission.
- The Commission upheld the termination, finding the post did not address a matter of public concern and could be viewed as racist or insubordinate; it credited Mayor Bland’s testimony that he verbally delegated authority to Chief Lee.
- Meadors appealed to the Lauderdale County Circuit Court, which reversed, concluding the Mayor’s unsigned termination rendered the action invalid; the circuit court did not reach the First Amendment claim.
- The City appealed to the Mississippi Court of Appeals; that court reversed the circuit court, holding the Commission’s decision was supported by substantial evidence, the verbal delegation was sufficient, and Meadors’s post was not protected speech on a matter of public concern.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the circuit court used the proper standard of review for Civil Service Commission appeals | Meadors argued the circuit court could review and reverse due to defects (e.g., lack of mayoral signature) | City argued circuit court improperly reweighed credibility and evidence; review is limited to whether Commission acted in good faith for cause | Court held circuit court erred; it should not re-make credibility determinations and must ask whether Commission acted in good faith for cause |
| Whether lack of the Mayor’s written signature invalidated the termination under Eidt | Meadors relied on Eidt to argue an unsigned termination required reinstatement | City relied on evidence (Mayor’s testimony) and Beasley to show appointing authority can confirm/authorize terminations even if initial notice lacked a signature | Court held Beasley controls: verbal delegation/confirmation credited by the Commission sufficed; termination valid |
| Whether Meadors’s Facebook post was protected First Amendment speech | Meadors contended his post was private speech and protected as addressing public concern | City argued the post did not address public concern, was racially insensitive and violated MPD conduct rules; public perception and discipline interests prevail | Court held the post was not speech on a matter of public concern and discipline did not violate the First Amendment |
| Whether substantial evidence supported the Commission’s finding of cause and good-faith application of discipline | Meadors argued evidence did not support cause or proper process | City argued the Commission heard testimony, credited the Mayor’s delegation, and found policy violations (race, insubordination) | Court held substantial evidence supported the Commission’s findings and its good-faith application of disciplinary procedures |
Key Cases Cited
- Eidt v. City of Natchez, 382 So.2d 1093 (Miss. 1980) (unsigned discharge by subordinate invalidated where no appointing-power confirmation)
- Beasley v. City of Gulfport, 724 So.2d 883 (Miss. 1998) (appointing authority’s confirmation can validate a termination despite initial unsigned notice)
- Garcetti v. Ceballos, 547 U.S. 410 (U.S. 2006) (public-employee speech is protected only when made as citizen on a matter of public concern)
- Locurto v. Giuliani, 447 F.3d 159 (2d Cir. 2006) (government may consider public perception of employees’ expressive acts when job involves public contact)
- Tindle v. Caudell, 56 F.3d 966 (8th Cir. 1995) (off-duty racially offensive conduct not protected as speech on public concern)
- Green v. Franklin Nat’l Bank of Minneapolis, 459 F.3d 903 (8th Cir. 2006) (use of racialized terms/imagery can constitute actionable racial harassment)
- Renfro v. City of Moss Point, 156 So.3d 913 (Miss. Ct. App. 2014) (appellate courts must not reweigh Commission credibility findings)
- Necaise v. City of Waveland, 170 So.3d 616 (Miss. Ct. App. 2015) (standard of review: whether Civil Service Commission acted in good faith for cause)