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Youth Crisis Center of the James T. Strickland Youth Center v. Moulds
Citations: 567 So. 2d 319; 1990 Ala. Civ. App. LEXIS 148; 1990 WL 34200Docket: Civ. 7227
Court: Court of Civil Appeals of Alabama; March 27, 1990; Alabama; State Appellate Court
Alma Moulds was terminated from her position at the Youth Crisis Center on July 7, 1988, for conduct unbecoming a public service employee, following a pre-disciplinary hearing where the chief probation officer recommended her dismissal. Moulds appealed her termination to the Mobile County Personnel Board, which upheld the dismissal. Subsequently, the Circuit Court of Mobile County vacated the Board’s decision and ordered her reinstatement. Both the Center and the Board appealed this ruling. The appellate court's primary issue was whether substantial evidence supported the Board's decision to terminate Moulds. The court emphasized that its review is confined to the record before the Board, affirming the Board's judgment if substantial evidence exists. Definitions of "substantial evidence" were noted, indicating it must provide a rational basis for the Board's conclusions and be adequate enough to support a factual determination that would withstand jury scrutiny. The court found substantial evidence supporting the Board’s decision, reversing the Circuit Court’s ruling. Six witnesses testified for the Center, detailing incidents where Moulds displayed intimidating behavior, including wielding a baseball bat to threaten residents and becoming volatile with them. Additionally, she faced disciplinary action for insubordination following a confrontation with a superior and made threatening remarks about a video store employee related to her employment, perceived as threats against the employee’s children. The Circuit Court’s finding that these comments were not corroborated was contested by the appellate court, which concluded they were indeed threats that warranted Moulds’ termination. Two witnesses testified that the appellee’s remarks were perceived as threatening. The appellee argued that her statements were protected speech, but this argument was rejected by the circuit court, which is limited to reviewing the Board's record. The appellee did not claim during the Board's review that her statements were constitutionally protected; instead, she argued her intent was not to threaten the video store employee. The Board disagreed with her defense, and there was substantial evidence to support its decision to affirm her dismissal. The circuit court's decision to vacate the Board's order was found to be erroneous. Consequently, the case is reversed and remanded with instructions for the circuit court to issue an order consistent with this opinion. Ingram, P.J. and Robertson, J. concur.