PAMELA J. ECKLER, APPELLANT,
v.
ORANGE COUNTY, FLORIDA, APPELLEE
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Pamela Eckler, a corrections sergeant, was terminated for using excessive force on an inmate, among other alleged misconduct. The court affirmed her termination, holding that when an employee is fired for multiple reasons, termination need not be reversed merely because some reasons are inadequately proven, so long as at least one valid ground for termination is supported by the record.
When a termination order does not indicate that termination was justified only because of multiple violations, the termination should be upheld if any valid reason is supported by the record. Termination need not be reversed merely because some alleged grounds are inadequately proven.
[1] A termination from employment will be upheld if at least one of the stated grounds for termination is adequately proven by the record, even if other grounds are not.
[2] An employee's termination from a corrections department is appropriate when excessive force is used against an inmate.
Previewing 2 of 5 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“when the order of termination does not indicate that the termination was only justified because of multiple violations, the termination should be upheld if any valid reason is supported by the record”
Establishes the core holding that termination need not be reversed if at least one adequate ground for termination is proven, even if other alleged grounds are not.
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Join FLexlaw to unlock all legal intelligenceEckler required an inmate who intentionally flooded his cell to lie face-down in the standing water while handcuffed. Eckler stepped on the inmate's b…
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HARRIS, J.
Eckler, a sergeant with the Orange County Corrections Department, was terminated for requiring an inmate who, in order to be relocated away from his cellmate, “Spiderman,” had intentionally caused his commode to overflow and flood his cell with a quarter inch of standing water to be handcuffed and to lie face down in the water. Eckler also stepped on the inmate’s back pushing his face to the floor. When the inmate spat out water, Eckler was found to have slapped him and slid him back and forth in the water “like a mop.”
In addition to the use of excessive force, other grounds for termination relied on by Orange County were that Eckler filed a false (incomplete) report and advised a subordinate not to file a report. The Circuit Court, sitting in its appellate capacity, considered the matter on certiorari. The issues raised by Eckler were that the grounds for termination were not adequately proved and, even if they were, her termination was a disproportionate remedy. The court determined that although the County had failed to adequately prove a false report and the attempt to have a subordinate not file a report, it had adequately proved the charge of excessive force and upheld the termination as appropriate.
The issue before us, although not considered below1, is whether a termination based on multiple reasons, any one of which is adequate for termination, must be reversed when one or more of the reasons, but not all, are found not to have been adequately proved. In other words, Eckler questions whether she would have been terminated had the County found her guilty only of using excessive force. We believe the better policy, consistent with the action of the appellate division of the trial court and consistent with the high expectation that those in control of our penal institutions will exercise their extreme authority reasonably, is that when the order of termination does not indicate that the termination was only justified because of multiple violations, the termination should be upheld if any valid reason is supported by the record.
Therefore, because the trial court afforded Eckler procedural due process and applied the correct law, we deny certiorari.2
PETERSON and PLEUS, JJ., concur. . Because this issue was not before the court below, it is difficult to find that it applied the wrong law.
. We treat this appeal as a petition for writ of certiorari. See Rule 9.040(c), Fla. R.App. P.
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Dorian v. Stefan Davis, 874 So. 2d 661 (Fla. 5th DCA 2004)…oval of the Development Plan. In general, a local government’s quasi-judicial decision, such as Orange County’s in this case, should be upheld if there is any competent, substantial evidence in the record to support it. See Eckler v. Orange County, 763 So. 2d 545 (Fla. 5th DCA 2000) (determination upheld even though only one of the three reasons given for termination were supported by the record); Hernando County Board of Commissioners v. S.A. Williams Corp., 630 So. 2d 1155 (Fla. 5th DCA 1993), rev. denied,…
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Orange Cnty. v. Butler, 877 So. 2d 810 (Fla. 5th DCA 2004)…departed from the essential requirements of law. A local government’s quasi-judicial decision must be upheld if there is any competent, substantial evidence supporting it. Dorian v. Davis, 874 So. 2d 661 (Fla. 5th DCA 2004); Eckler v. Orange County, 763 So. 2d 545 (Fla. 5th DCA 2000) (holding that a quasi-judicial determination by a local government should be upheld if any valid reason is supported by the record). As a result, we grant Orange County’s petition for writ of certiorari and quash the circuit cou…