EDWARDS v. CITY OF SALLISAW, 2014 OK 86

Edwards, elected police chief of Sallisaw, faced an ordinance removing his supervision/management authority over the Police Department while he retained title, salary, and duties of office.
Sallisaw operates under a charter with a commissioner-manager form, giving the board of commissioners power over police duties not defined by the charter.
Ordinance 2013-01 repealed 54-31 and authorized the City Manager to supervise and manage the Police Department, for at least 90 days, with Edwards retaining rank and salary.
After enactment Edwards continued as chief in title and salary; a captain supervised day-to-day operations, reporting to the City Manager, while Edwards did not supervise the captain.
Edwards sought declaratory and injunctive relief; the district court denied summary judgment and issued an injunction; appellate review was retained; the district court’s order was vacated and remanded with instructions.
The court focuses on whether the charter permits limiting the police chief’s powers by ordinance and whether due process was satisfied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May a home-rule city charter allow the board to limit a police chief’s duties by ordinance?	Edwards claims inherent supervisory authority exists beyond charter powers.	Board may set duties not detailed in the charter by ordinance.	Yes; ordinance properly sets duties; Edwards lacks inherent supervisory power.
Did the ordinance removal implicate Edwards’s due process protections?	Removal of supervisory ability without proper procedures violates due process.	Edwards was not removed from office; due process satisfied.	No due-process violation; Edwards retained office, salary, and privileges.
How should the Sallisaw charter be construed in this context?	Charter implies broader inherent police-chief authority.	Charter terms are plain; duties not in charter require ordinance or statute.	Charter is plain and unambiguous; board may assign duties by ordinance consistent with statute.

Nottingham v. City of Yukon, 1988 OK 130 (OK (1988)) (whether certain powers are incidental to administrative authority depends on charter language)
Moore v. Oklahoma City, 1927 OK 49 (OK (1927)) (city charter can set manager/chief duties, without infringing state police duties)
State ex rel. Burns v. Linn, 1915 OK 1037 (OK (1915)) (state interest in enforcement of general laws; municipalities cannot claim sole control over state-law duties)
City of Senter v. Muskogee, 1939 OK 375 (OK (1939)) (charter interpretation of executive powers must align with statutory framework)
Thurston v. Caldwell, 1913 OK 714 (OK (1913)) (state sovereignty limits on municipal control over police matters; framework for municipal duties)
Land v. City of Sapulpa, 1924 OK 92 (OK (1924)) (municipal taxation/state interest and municipal autonomy in local matters)