HomeMy WebLinkAbout1982-02-02; City Council; 6890; Personnel Board action.. Z 0 6
8
a 2 0 Z 3
46#-
MTG. 2/2/82
DEPT. PER
.--
.I
CITY AllY
TITLE DEPT. HD.
PERSONNEL BOARD ACTION
CI1.t OF CARLSBAD - AGEND, . BILL
It is recommended the City Council affirm the action of the Personnel Board as set forth in Personnel Board Resolution No. 2.
ITEM EXPLANATION:
WILLIAM J. SMIGIEL, Sr. appeared before the Personnel Board on December 3, 1981, to appeal his dismissal from city employment. The Personnel Board heard the appeal and sustained the dismissal, Personnel Board Resolution No. 2.
A copy of the verbatim transcription of the hearing is available for review in the office of the City Clerk.
FISCAL IMPACT:
The estimated fiscal impact consists of staff time involved in scheduling, hearing, and transcribing the board action.
EXHIBIT
a-Personnel Board Resolution No. 2 b.Copy of transcript of SMIGIEL hearing of December 3, 1981.
I
1
2
3
4
5
6
7
8
9
3.0
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
RESOLUTION NO. 2
A RESOLUTION OF THE PERSONNEL BOARD OF THE CITY OF CARLSBAD, CALIFORNIA, ANNOUNCING ACTION ON THE APPEAL OF WILLIAM J. SMIGIEL. SR,
WHEREAS, the Personnel Board of the City of Carlsbad,
California, met on December 3, 1981, to hear the appeal from
termination of William Smigiel, Sr.; and
WHEREAS, the Personnel Board heard evidence and argument
presented by the city and Mr. Smigiel; and
WHEREAS, the Personnel Board after consideration of all the *.
evidence and argument finds that: (a) Mr. Smigiel is unable to
perform the work required for the classification of Maintenance
Worker I and (b) Mr. Smigiel presented no evidence indicating
his abil.ity to perform the work required of a Maintenance Worker I.
NOW, THEREFORE, BE IT RESOLVED by the Personnel Board of
of the City of Carlsbad, California, as follows:
1. That foregoing recitations are true and correct.
2. That the termination of Mr. Smigiel should be sustained.
PASSED, APPROVED, AND ADOPTED at a regular meeting of the
Personnel Board of the City of Carlsbad, California, on the 3rd
day of December , 1981, by the following vote, to wit:
AYES: Richardson, Bates, Mitkevich, Osuna, Watkins
NOES:
ABSENT :
7 --) . -\ ; (’
1- -’ /
,
,’ I
,.----2- <id ,/ _, -4 , qkdl/&&$$#
il IChairrnpirTdf‘ the
ATTEST:
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Richardsoa7
18
19
Smigiel 20
23
24
25
26
27
28
CITY OF CARLSBAD
Meeting of : PERSONNEL BOARD Lyle Richardson, Chairman Date of Meeting : December 3, 1981 Donald Watkins, filember
Time of Meeting : 7:OO p.m. Jack Osuna, Pember Place of Meeting: Council Chambers David Bates, Member
. Camille Mitkevich, Member
I The Personnel Board of the City Council of the City of Carlsbac
was called to order by Chairman Lyl& Richardson, 7:05 p.m.,
Thursday, December 3, 1981, in Carlsbad City Hall Council Chambers.
The Chairman directed the Recording Secretary to show that all
members of the board Qere present.
Appellant Employee, and family; Dan Hentschke, City Council
Representative; Jerome N. Pieti, City Representative; Mr. Robert'
Metcalf, City Witness; City Employees Witnesses BALDWIN, BROWN,
MITCHELL; City Observer Frank Mannen, Assistant City Manager/Admin.
The record will show others in attendance were William Smigiel;
Chairman Richardson introduced new board member CAMILLE
MITKEVICH.
(Following is a transcript of the Hearing of the Case 05
WILLIAM. J. SMIGXEL vs the City of Carlsbad.)
This hearing is being held in accordance with Rule XVI, Personnel
Rules and Regulations for the City of Carlsbad. Know that those
present at this hearing have received a letter of notice.
you receive this notice, blr. Smigiel? .
Yes, I did.
Fine.
preside at this hearing and I am responsible for the proper and
orderly conduct at this hearing.
that all facts are fully developed, made a part of the board's
proceedings.
all the facts. These facts must include all matters, favorable
and unfavorable, which are properly a part of the case. On the
basis of these facts this board will make its recommendations.
In accordance with Section 5, Rule XVI, Resolution No. 6423,
this shall be a fact finding hearing and the rules of evidence
shall not necessarily apply.
Did
The appellant filed a timely appeal, As Chairman I shall
It is up to the board to ensure
No board can properly evaluate a case without having
All witnesses will be sworn and will
1:
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Smigiel 17
Richards0 f8
19
20
21
22
23
24
25 Smi g ie 1
Richards-
27 Smigiel
Richardson
28
I
Page 2 of 23
be subject to examination by the grieving employee, an employee
representative, members of the board and council.
which would render him unable to afford the appellant a fair and
impartial hearing?
Now, is there any member of this board aware of any reason
Let the record reflect that all members answered in the
negative. e.
Mr. Smigiel, you are advised that as the grieving employee
You may be present at the open proceeding of this board.
You may be represented by any person or attorney at all open
You or your counsel or representative may question any
You shall state your case first.
You may call witnesses.
You did not supply the board any documentary evidence, so you
will not be able to present anything that has not been presented
to the board before this time. Unless, Mr. Smigiel, you had
good cause for not doing so, We will give you an opportunity to
say so if you have documents to present.
No, I don't. I just have a statement to make.-
You and your counsel, of course, may examine any exhibits
thus far received in evidence, And, at any time during these
proceedings you or your counsel may submit in writing any brief,
argument within the range of affairs of the matter under investiga
tion, that you may desire to bfing before the board.
You may take the stand and be sworn as a witness, in which ca
you may be subjected to cross exm'ination'just as any other witnes
before the board. Or, of course, you may remain silent.
in this hearing you have the following rights:
proceedings.
witness who testifies before the board.
Do you have any questions regarding the procedures of the
conduct of this board, Mr, Smigiel?
No, .I don't.
Do you have any witnesses that you will be calling this evening?
No, I don't:
Will you be calling yourself as a witness? .
e
- . . ._ ..- - - - __ .... i ^I .. - .-_.---. . . ..
Smigiel 1
Richardson 2
Smigiel 3
Richards03
Pieti 5 Richardson
Pieti 6
7
8
9
10
Richards0 fi
Pieti 12
13
14 Richardson
15
16
17
sncigiel 19
2c Richardson
21
22
23
24
Smigiel
25
26
27
28
Page of 23 -
..
I wish to read a statement.
You-may make a statement, but without being sworn as a witness.
Will you be a witness?
No, I won't.
Does the city, Mr. Pieti, have witnesses that you will be calling?
Yes, sir, we have witnesses.
Please ask them to stand and identify themselves.
I would like to Tntroduce Mr. William Baldwin, Assistant City
Manager for the Maintenance Operation; Chuck Mitchell who is a
supervisor in the Maintenance Department; Don Brown who is a
Street Superintendent in the Maintenance Department and Robert
Metcalf who is a consultant with J. Faire and Associates, a
rehabilitation counseling service.
Gentlemen, you will please stand and raiseyour right hand at
this forum. . . . and I will be giving some information which could be considei
evidence as part of my presentation, and I would like to be sworn
in.
Please raise your right hand.
evidence that you shall give in the matter now before this
hearing is the truth, the whole truth, and nothing but the truth,
so help you God?
(The record shows a chorus of I D0"S. )
Mr. Smigiel, you may make your opening statement.
I would just . .
exactly why they did fire me.
Mr. Smigiel, you are here as the appellant. You are here to
present your case, your evidence. You are asking the Personnel
Board to rule on an appeal that you have made.
rule in the matter you must present your case or there is no case.
F7ell, like I said at the beginning, I'll make a statement and
if that's what you want to make a case out of we'll go from there.
I do not f,eel that it was a fair decision for the City of Carlsbad
to fire me. I was going to make a big issue of this, but I feel
it only fair to my family and myself to try to make this brief.
The city's memo of 11/24/81, the subject of this hearing. . . Thi:
is all I have, I guess. The one basic flaw in the memo is that
Do you solemnly swear that the
I guess 1'11 leave it up to the city to tell me
What reasons.
For the board to
ed
-.
1
2
Richardson3
4
5
6
Smigiel
Richardson7
8 Smigiel
Smisiel 10
Richardson 9
T-J. Richards0
Smigiel
12
13
15
16
17
. 18
19
20
21
22
23
24
Richardson
25
26 Smigiel
27
28
--
-.ige 4 of 23
I do-not feel that the action of the city abides by the state
labor code.
Now we go to the following documents that the city has presented.
Mr. Smigiel, we will take the evidence from the city as it is
presented. At this point it has not been presented. Please make
your opening statement and keep to that.
Well, I guess I'm a little green on this, because I just have this
statement to make. 8
Briefly tell us what is your grievance; what is your complaint;
what is your appeal, Mr. Smigiel?
My feeling is that I see no basis for me being fired.
You were fired from the city on what date, sir?
On the 22nd of October.
And the reason given?
In the notification of discharge of employment from the City of
Carlsbad at the end of working hours on October 22nd and the reasor
for this action is my inability to perform the €unctions of the
classification of Maintenance Worker I in the Street Division.
They claim that this was verified by Dr. Greenfield of San Diego,
reporting an examination of March 10, 1981. . . .and since that
date my disability has become permanent and stationary and that I
have been employed in a modified assignment.
assignment is not a permanently budgeted position and cannot be
continued. Therefore, no position exists in the organization
for me. It goes on that because no position exists that I have
?.
You can put it in your own words.
This modified
twice been offered the opportunity for rehabilitation in another
occupation and that I have twice refused.
I tell you right now that I never refused it.
that is. I asked postponement on it. The rest is just to say that
I will be paid on such a date and stuff.
Mr. Smigiel, you say that you were dismissed on October 22nd as
a Maintenance Worker I in the Street Department, right? Are
you saying that you could perform the duties?
Well, I'll have to say that I don't know 2f I could perform the
duties. I never really went back to my regular duties. I came
back to work in February and the first couple of days I came
back I had a lot of problems with my leg and f couldn't perform
the duties.
As we get along to that,
Rehabilitation,
Richardsod
2
3 Smigiel
Richardsod
5
6
Smigiel 7
Richardsone
9 Smigiel
Richardsohc
Smigiel 11
Richardson I2 Watkins
1:
Smigiel 14
Watkins If Smigiel
Watkins It
Smigiel 1:
Watkins It
Smigiel
Watkins 2(
2:
Smigiel 2:
2:
Watkins 24
Smigiel 2l
Watkins 2' Richardson
2;
Pagt .I of 23
Jell, we're getting into argument'now of the statements.
should be sworn as' a witness,
You
Do you agree? Would you care to be
;worn?
hre.
?lease stand, raise your right hand. Do you solemnly swear that
the evidence you shall give in-this matter now in this hearing shal
De the truth, the whole truth and nothing ,. but the truth, so help
fou God?
Yes, I do,
YOU say at this point that you were not given the opportunity to
perform your duties?
Not within the last six months before my termination.
Hhat else do you have to add, Mr. Smigiel?
That's about it right now,
Do any members of the board have questions?
Mr. Smigiel, you had an industrial accident commission hearing, is
that correct? In August?
I had one, yes.
You were granted a disability rating?
Yes, I was.''
What was the degree of the rating?
18%.
In the comments when that rating was issued, did they indicate
that it would impair your ability to perform physically?
It differed from doctor to doctor.
Did the Industrial Accident Commission concur on the rating of
18%? . . .and what is your understanding of that 18% disability
rating?
Yes they did. To tell you the truth, I really don't know what
the rating means. I guess 18% of my body is no longer of use.
Would it be a reasonable statement then, or presumption to say
that you were at least 18% deficient in being able to perform
the physical duties required of your job?
Yes.
No further questions.
Do we have any further questions from'the board?
questions of this witness from the city?
Do we have any
lf there are no further
1
2
Pieti 3
4
a
9
10
11
12
13
14
15
Ric ha.rd sa6
Pieti 17
18
Richards&'
Pieti 20
21
22
23
24
25
26
27
28
-.
Page of 23
questions of this witness we'll proceed with the testimony of
the city. Mr. Pieti, you may present your case.
The city's opening staement is very brief and it is the city's
contention, and the city will show, that the action of the city
was proper in that it did comply with the existing laws, rules
and regulations, that are applicable to the city and its employees
The sequence of this action was to-inform Mr, Smigiel of the city':
intention to dismiss him. . .and the reasons. . . , providing him
an opportunity to respond and to appeal. , .which he did. , ,
which resulted in this hearing scheduled this evening. The city
contends that the dismissal was appropriate. We say appropriate
in that it was the'only action which could serve both Mr. Smigiel
as an employee and the city as an employer. The action served
both parties by providing for rehabilitation for Mr. Smigiel
from a classification and task he could no longer perform, providii
J.
him with temporary disability payments and permitting him to
be trained for full employment in the future. The action served
the city in that it provided an opening in a position of
Maintenance Worker I which it was unable to fill as long as we
retained Mr. Smigiel.
Mr, Pieti, you may call your witnesses.
I would like to call Mr. Robert Metcalf of J. Faire Associates
as my first witness. We could either have Mr. Metcalf at the Stan1
0.0
I think he can sit right there at the table. That will be fine.
Before I begin talking to Mr. Smigiel. . . I mean Mr. Metcalf
about Mr. Smigiel, I would like to state the stipulations that
were made to the board. I just would like to restate them prior
to beginning this. First of all, we stipulated that Mr. Smigiel
was dischaggGd as an employee, as he stated, on the 22nd of
October 1981 by the City Manager. Second, we stated that the
dismissal complied with the personnel rules of the City of Carlsba
and existing state law. Third, that Mr, Smigiel has sustained
an industrial injury to his left knee on or about September 21st,
1979. Four, that the above mentioned industrial injury resulted
in a finding of a permanent disability of 18% by a Workers
Compensation Appeal Board decision. This was Case #80SD6132,
3
1
2
3
4
5
6
7
a
9
10
11
12
13
14
15
16
17
. 1E
. 19
2c
21
22
22
24
25
26
27 Met calT
28
Page of 23
dated August 7, 1980.
Having restated the stipulations made to the boardl the city
would now like to provide information which would provide a transi-
tion from the stipulated information to the testimony that we
are about to hear on behalf the city.
Following Mr. Smigiel's injury in 1979 he worked off and.on for
the balance of 1979.
he was back at work. Subsequently; following the injury he
underwent surgery for the knee and he ended up being placed on
industrial leave, which under the City of Carlsbad personnel
rules permitted an employee with an industrial injury to be out
for a period of ninety days.
leave he had not recovered sufficiently to return to full duty
and he was placed on a leave of absence without pay.
purpose of this was to continue his status as a city employee,
giving him all rights, benefits, and privileges that belong to a
city employee, although he did not draw pay.
He remained in that status, at his request and upon approval
of the City Manager, until his doctor, Dr. Helgager reported to
the city that his injury was sufficiently improved for him to
return to work. And as he has just stated, he then returned to
He had some sick days'and he had some days ,.
Following the period of industrial
The
work on February 2, 1981. Right at that point the city took
action of its own and based on the evaluations, the visual
evaluations of his condition, and the tasks he was to perform, the
city asked J. Faire Associates to do a task analysis of Main-
tenance Worker I in the Streets Division and we sent a copy
of that taSk analysis to a doctor selected by the city, along
with Mr. Smigiel, for a reexamination of his knee. And it was
based on these acts that we arrived at the conclusion that at
that point Mr. Smigiel should be placed in modified assignment.
NOW, I'll get to the place where we had J. Faire Associates do
a task analysis.
view of what the tasks of his classification were. Mr. Metcalf
would you tell us what your title is and who your employer is?
My title is Certified Rehabilitation Counselor and I work with
a group of rehabilitation counselors called J. Faire Associates,
based in the City of San Diego.
This was done so that we had an outside objectivi
Pieti
Metcalf
Pieti
Metcalf
Pieti
Metcalf
Pieti
Net cal f
Pieti
Metcalf
Pietr
Metcalf
Pieti
Met c a 1 f
Pieti
Metcalf
Pieti
Metcalf
Pieti
Me tca 1 f
1
2
3
4
5
6
7
a
9
3.0
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
& Page of 23
Do you know Mr. Smigiel?
Yes, I know Mr. Smigiel.
Have you counseled Mr. Smigiel concerning rehabilitation?
Yes, I have.
Is Mr. Smigiel currently undergoing rehabilitation?
Yes, he is attending Southwest Trade School in electronics
technicians, *.
Does he receive any compensation while he is undergoing this
training?
My understanding is that he receives $154 per week plus mileage.
How long do you anticipate his rehabilitation training,will
continue?
The plan that I have drawn up calls for.him to start school on
November 16, 1981, which he did. And to complete his training
there Kay 21, 1982. And then he is to have 60 days of placement
assistance, The plan would terminate about July 16, 1982.
Based upon your experience, what would you estimate his employ-
ment opportunities upon completion of this training?
If he successfully completes the program, they have had 100%
placement rating out of the school.' There is a strong demand
for electronics technicians. So, I think that he will have an
excellent chance of being employed.
And following initial employment, do you think there is an exceller
chance of Mr. Smigiel having continued employment in this category:
Yes, I do.
The board has a copy of the J. Faire Associates job analysis
for the city position of Maintenance Worker I in the Streets
Division. Did you do this job evaluation?
Yes, I did.
Do you consider this to be an adequate or a fair evaluation of
the tasks involved for a Street Maintenance Worker I?
Yes, I do.
And how do you conclude that?
I received a written job description from yourself in the personnel
office and then I came over to the maintenance yard and talked
to Dude Greagrey, who took me around the yard and drove me around
and explained the various tasks involved in the street maintenance
How did ybu reach that conclusion?
t
. . '. __ . .. , . . . . - .. --~ ... >. . .. __.____-__.._-. .. . .. "&. . .
1
2
3 Pieti
4
5
Metcalf 6 Pieti
Richardson7
Smigiel e
9
Metcalf
11
12
1Z
14
15 Richardson
Bates 1E
lri
1€
15
Metcalf 2c
21
22
Richardsa
24 Smigiel
2f
Metcalf 2(
27
2E Pieti
4I -
Page of 23
work.
Dictionary of Occupational Titles and included that.
I got a faik representation of what was involved in the job.
And that, to the best of.your knowledge is the evaluation that
was then returned to the city and subsequently forwarded to
the city doctor?
Yes.
I have no further questions of Mr. Metcalf.
Mr. Smigiel, do you have any questions of Mr. Metcalf?
Then I looked up the definition of the position in the
So I think
e.
Just one. You said I have six months from May 21st, the day my
school ends.
catch on to the new job, what happens to me then?
Usually what I do. . .
twice a month to see how you are doing.
two or three months we find that you are not cutting it in
electronic technology then we'll do a further evaluation to see
why. Maybe its not your thing or maybe you don't have the
aptitude for it. If we find that is the case then we will have
to change objectives and come up with another plan.
Do any members of the board have any questions for Mr. Metcalf?
Yes, I do. Mr. Metcalf, in your experience as a rehabilitation
counselor do you sometimes analyse a job as you'v6 done here,
then analyze the individual's physical capabilities and try to
match him to the job and form any conclusions as to what they
can physically perform on the job you analyzed?
Normal procedure is for me to develop the analysis and submit it
to the doctor because that is a medical judgement and so I don't
make those judgements. I have my opinions but I don't make them
known.
Yes, Mr. Smigiel?
Can I have one more question? Mr. Metcalf, to the best of your
knowledge, have I ever refused rehabilitation through you or
anyone at any time?
No, to my knowledge what occurred is that you informed us that
you preferred to return to your modified work at the city, to try
that and that you would like tb postpone your rehabilitation.
If there are no further questions of Mr. Metcalf, I would request
If it so happens that for some reason that I can't
As you know I check in with you at least
If Githin the first
. . "._ ._ .. . . . . . _- , .. ", . *I..-
1
2
Pieti 3
4
5 Mitchell
6
Pieti 7
Mitchell
Pieti 8
Richardsong
. 10
11
12
Mi t che 11
Richardson
Pieti 13
14 Mitchell
15
Pieti 16
17
18
19
20
21
Mitchell 22
23 Pieti
Mitchell
24
25
26
27
28
Piett
Page .I of 23
that he be excused, He has some illness in his house and he would
like to leave.
(The record will show that Mr. Metcalf was excused at 7:27 p.m.)
I would like to call Chuck Mitchell. Mr. Mitchell could you
state your full name, your classification, your title and the
division and the department you work in.'
Chuck Mitchell, Street Department, Supervisor, and I work in
streets.
Do you know Mr. Smigiel? Were you his supervisor?
Yes, I do. I have supervised Mr. Smigiel.
How many years experience have you had in the streets division?
One question.
What dates?
Well, we have two supervisors and.we don't have one definite. . ,
Oh, I see. You cover all the times but notnecessarily with
the same group of men. Go ahead, Mr. Pieti.
How many years of experience do you have in the your division in
the Maintenance Department.
I have been in the streets division for a little over twelve-
years.
This is a classification description of the position of
'(street)-Maintenance Worker and I show this to you in this form as
a refresher. This is the classification Mr. Smigiel formerly
held with the city. Having observed Mr. Smigiel after he returned
to work in February of 1981, being familiar with the classificatio~
description and based on your experience, do you believe Mr.
Smigiel could continue to work as a (street) Maintenance Worker I
in the City of Carlsbad?
No, I do not believe he had the physical capability to do it.
Were there any specific instances that you can recall?
Well, when he first came back he had a lot of trouble with his
leg,
bother him.
that his leg hurt, that he couldn'kdo that, so we had to keep
trying to find odd jobs for him to do.
You made these modified assignments and you employed him pretty
. '.
-
You were supervisor part of the time. What time?
He would come back and work a day or two and his leg would
We would give him several jobs and he would complain
much in these modisied assignments up until the time he left the ci
Mitchell 1
2
3
Pieti 4
5
Mitchell
Pieti 6
7
Mitchell 8
Pieti 9
Mitchell 10
Pieti 11
12 Mitchell
Pieti 13
Richards=
Smigiel 15
16
Mitchell 17
18
Smigiel 19
20
21
22
Mitchell 23
24
25
26
Richards0
Mitkevich 87
28
Page .I of 23
He was working in the sign shop making signs, doing odd jobs
for awhile and then'we put him on as an electrician helper on the
truck helping the electrician. We don't have an actual classi-
fication for electrician helper.
Do you have any type of budgeted position for electrician helper
or any other of the modified assignments he held when he returned?
No, we donl-t.
Are there any classification descriptions for any of the positions
that you are aware of?
h
None that are without physical capabilities of doing the job.
In your opinion is there a need in the division now for any special
assignments such as the ones that were provided for Mr. Smigiel?
Not in my opinion.
So, what you are telling us is that there, essentially, was no
work to be performed by Mr. Smigiel?
Not classification type work, no.
I have no further questions.
Mr. Smigiel, do you have any questions?
Yes. Mr. Mitchell, since I came back to work in the street
division in 1979 approximately how many times were you my direct
forman who Qave me any orders?
I can't even recall. Off and on. There's no telling how many
times. For the record, Dude Gregory C;Tas,for the better part of
time, your direct supervisor.
The other thing I would like to ask you is, as far as this
electrician helper which the city has no call for, would you
agree that it is customary for anyone that is injured in the
department to be sent out as an electrician helper, anyone else
beside myself?
Well, at the time we felt it might be useful to have a helper
on the truck in case something went wrong and the electrician
was in a building for a long period of time. But, it was no
city. classified job and since you have left, we haven't had a
helper.
Any questions by any member of the board to Mr. Mitchell.
Yes, Mr. Mitchell, when was the last time that Mr. Smigiel was
put in with the street crews to work that you found he was incap-
able of doing the job?
Mitchell 1
2
/.
3
Mitkevich 4
Mitchell
Richardson 6
7
Hitchell 8
Richardson
Pieti
Browfl
Pieti
Brown
Pieti
Brown
Pieti
Brown
9
10
11
12
13
14
15
16
17
le
19
2c
21
22
2:
24
25
26
27
2e
- Page 2 of 23
He was put in off and on for three or four months after he origi--
nally came back from his injury and was released from the doctor,
at which times he complained that his knee was still bothering
him.
Can you give me a month?
I couldn't give you a month.
Mr. Mitchell is it your testimony that theri? are certain normal
duties that are performed by a strGet maintenance worker that
Mr. Smigiel says that he could not perform?
Yes, there are.
Any further questions from the board? Mr. Pieti?
I would like to call Don Brown. Mr. Brown would you state your
name, your title, your division and the department in the city
in which you work.
My name is Don E. Brown. My title is Street Maintenance
Superintendent in the street division of the Maintenance Department
with the city.
How long have you served in the capacity of Street Maintenance
Superintendent?
Since about 1970.
I'll show you a copy of the classification description which was
used by J. Faire and Associates for reference if you need it.
is a classification which was held by Mr. Smigiel when he was a
city employee. Based'on your experience and your knowledge of the
classification, are you of the opinion, having observed Mr. Smigiel
as superintendent on his return to work, that he could perform
the functions of the Maintenance Worker I.
No,I don't think he could.
This
Why do you. . . What do you base that opinion on?
Well, there were several instances that we would put him in a
xew and his knee would bother him; he couldn't shovel, since it
uould bother his knee. Basically, it was the knee. We put him
to driving the truck now and then.
Je came in with a doctor's release that specified that he was on
nedication and couldn't drive. He just was physically unable to
30 the jobs assigned because of his knee or the medication.
He was on medication at the time
Pieti 1
2
3
Brown 4
Pieti 5
Richardson
Smigiel 6
7
Brown a
9 Smigiel
10
Brown 11
Smigiel 12
Brown l3
14
15
Smigiel 16
Brown 17
Richardson 18
Smigiel 19
Richardsw
21 Brown
Richards&
Brown 23
Richardson 24 Brown
RichardsA5
Bates 26
27
28 Brown
A Page 3 of 23
So, he was employed in a modAfied assignment. Do you see as
Street Maintenance Superintendent a need for a continuation of
the modified assignment such as Mr. Smigiel was given in the
streets division?
Not on a continuing basis, no.
I have no further questions. -
Mr. Smigiel, do you have any questions for Mr. Brown?
Mr. Brown, at any time that I was assigned under you, did 1 refuse
to work?
You told me several times that you could not perform shoveling.
You told me you couldn't shovel.
I asked you, did I ever refuse work. If you assigned me to some-'
thing did I ever say that I did not want to do it?
I just don't think that I could say that you said that, no.
In the statement here it says that. I have a statement here
that you wrote that says I refused to work.
To work, . . You couldn't work. You told me you couldn't work
and I asked you at times to go out on the boom truck, did I not
with the electrician? You said that you couldn't climb up in the
back.
I did not say that I couldn't climb up in the back, did I?
Certainly did.
We won't get into various arguments. If, Mr. Smigiel you wish
to disagree with the witness you can certainly present your case.
Thank you.
Mr. Brown, there were times that Mr. Smigiel told you that he was
unable to perform certain tasks that you wished to assign to him
Yes.
Were there any tasks outside of shoveling?
Driving. Couldn't drive.'
Anything else?
Those are two of the most common ones,
'Do any members of the board have any questions.
I just have one, Mr. Brown. At any time prior to Mr, Smigiel's
knee injury did he ever indicate that he was unable to perform
any of the duties?
At that time, no.
..
Watkins
Brown
Watkins
Brown
Wa t k in s
Brown
1
2
3
4
5
6
7
E
9
Watkins
11
12
12
Brown 14
Richardson 15
I€
lr;
, 21
Watkins 2;
2:
2f
2:
Smigiel 2e
Watkins
Bates 2';
2f
*- Page 2 of 23
Mr. Brown, it's your opinion that Mr. Smigiel, if he were to
return to work tomorrow morning, would not be able to, in your ---
judgement as a Superintendent of streets, be able to carry out
his duties. Is that Correct?
Unless there is some medical evidence to show different than I
have had since he left I would have to say that he would not be
Are you in your position aware of the budget in your department?
Yes.
Do you have an opportunity or responsibility to formulate
that portion of the budget that deals Gith your division?
Yes, I do.
Was the work that Mr. Smigiel doing budgeted at the time that
he was put on modified duty?
capable. ?.
(No. answer. )
If Mr. Smigiel were to return to work in a modified duty position,
what would the effect be on the budget in your department?
Probably at this time we would be overspent.
Mr. Smigiel, you heard your former supervisor or former boss
indicate that you have been unable in his opinion to shovel, to
drive--at least these are the two itemswhave. aa you have evidence
that would'indicate for this panel that you are, indeed, able
to do those things, plus the other tasks that are listed in
the J. Faire report outlining your job description?
I have a letter from the doctor saying I have stopped medication
and I could have driven.
of approximately two'or three months. It had nothing to do with
my leg.
What we're looking for to help us is whether or not you have
evidence. . . Apparently you didn't because I understand from the
chair there was nothing submitted that would show this board
that, in fact, that position which the city alleges is not true.
Do you have evidence to show us that?
No I don't at this time.
I have no further questions.
Mr. Smigiel, were there at any times duties normally assigned to
a maintenance worker refused--maybe not necessarily refused by
you--that you were unable to perform and that you told your
I was only on the medication for a perioc
..
only have 18% disability.
Let me ask you this.
here, but do you think it's fair for the City of Carlsbad to
continue to keep he position open for you to wait for an operatio
for this knee?
And maybe I'm getting a little far a5ield
Smigiel
Bates
Smigiel
Bates
Smigiel
Bates
Smigiel
Bates
Smigiel
1
2
3
4
5
6
7
e
9
Richards&
Watkins 13
1:
14
1:
lt
Smigiel
Watkins
1:
l!
2(
Smigiel 2;
Watkins 2:
20
21
Smigiel
21
2' Watkins
21
supervisors that you were unable to perform?
Yes, there was times I told my supervisor that.
I would like to know the last time that you were unable to perform
one of those duties.
That would probably be my driving.
And when was that?
Like I said. . ,. approximately. . . well, probably four months ago
five months ago.
How long prior to your dismissal?
Two to three months before my dismissal.
And, you couldn't drive because of your knee?
No, not because of my knee.
Anything else?
I have one. Mr. Smigiel, I'm calling your attention to a report
issued by Dr. Richard Greenfeld. You have that, dated March 10,
1981, right?
of the report.
the record?
Go right ahead.
The patient's disability precludes very heavy work. He has lost
approximately one quarter of his pre-injured capacity performing
such activities as bending, stooping, lifting, pushing, pulling,
or other activities involving comparable physical labor.
reviewing the patient's job description I doubt that he is going
to be able to perform these activities and I feel that either a
modified job within the City of Carlsbad or rehabilitation would
be required."
Mr. Smigiel?
Would I like to dispute it?
Did you dispute it to him when you received this?
him and say that this report is incorrect?
No, because I'm still waiting for another operation on my knee.
And I don't know if one quarter is equal to 25% disability.
I was on medication.
Your attention is directed to the last two paragraph
Do you have any objection to my reading this into
After
Did you ever dispute that statement from the doctor
Did you call
I
- ~ .. .. .. . .. .. . . I ..* ., .
Any questions from members of the board? 'No questions, Mr. Baldwil
I,
Smigiel 1
2 Watkins '
Richardson
3
Smigiel 4
5 Watkins
Smig-iel
6 Richardson
7
8
9
10
11
12
Pieti 13
14 Baldwin
Pieti
15
16
17
Pieti
Baldwin
19
20
21
22
23
24 Baldwin
Pieti 25
Richards
Smigiel
Richards&?
%
I
~
- - Page 5 of 23
They've done it for many other people.
That-*s all I have to say.
Mr. Smigiel, do you have medical opinions contrary to Dr. Green-
feldLs relative to the two paragraphs just read?
Yes, I do,
Do you have them here?
I don' t know. ,
Does anyone have further questions"of Mr. Brown? Mr. Brown, you
are excused. I think possibly that if Mr. Smigiel can find his
evidence that it can be presented at a later time. Mr. Pieti?
I would like to call Mr. Baldwin. PI. Baldwin,would you state
your full name and your position and the department of the city
in which you work?
William C. Baldwin, I am the Assistant City Manager/Maintenance
and Operations.
Maintenance for the city.
Do you know Mr. Smigiel?
Yes.
I show you a copy of the classification description of Maintenance
Worker I, streets, for your perusal and at the time Mr. Smigiel
was working in modified assignments in the Street Division you
were acting in a capacity as Assistant City Manager, but I know yo1
were familiar with Mr. Snigiel's case. You are currently with the
1 operations and maintenance section and have responsibility for the
I manage the Street, Equipment and Building
maintenance for the city's streets in conjunction with personnel
such as Mr. Brown and Mr. Mitchell. Based on your knowledge
of the classification, your work within the department, the infor- I
mation you have concerning the department's budget, do you see the
necessity for creating any type of modified position within the
department similar to the one that has been filled by Mr. Smigiel
over the last several months prior to his separation.
Not at this time.
I have no further questions.
Mr. Smigiel, do you have any questions for Mr. Baldwin?
No, I don't.
Mr. Chairman, those are all the witnesses that the city desires
1
2
3
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Richardso $0
21
. Pieti 22
Richardso $3
Smigiel 24
25
..
26
27
28
Richardson
Page 17 of 23
to present. We have attempted to show that upon receiving an
opinion from Mr. Smigiel's personal doctor, Dr. Helgagar, that
he could return to work. The city based upon the observation of
its supervisors and its managers sought to examine the question
further rather than aggravate an existing injury and provide a
deepened disability for a city emp3oyee. Consequently, we
requested 3. Fai're and Associates to do the task analysis which
has been presented to the board and to Mr. Smigiel. We forwarded
that to Dr. Greenfeld and that was followed up by an examination
of Mr. Smigiel by the doctor and we asked the doctor for a medical
opinion concerning Mr. Smigiel's ability to function as a Main-
tenance Worker I in streets. On the basis of those two opinions
he was provided modified assignments to sustain him as a city
employee until such time as the city could arrange for rehabili-
tation. At that time the city felt there was no economical nor
human need to be served in continuing this modified employment
and the offer for rehabilitation was made to Mr. Smigiel,
ultimately accepted. He was discharged. He is currently under-
going his rehabilitation training, receiving temporary disability
paymer-ts and mileage to and from the site of his training.
You have heard the estimates of his employment future from the
rehabilitation couselor, Mr. Metcalf. The city contends that
the city acted properly and appropriately and we would request
that the board sustain the dismissal by the City Manager, making
such a recommendation to the City Council.
Mr. Pieti, you have documents that you have presented in timely
fashion to the board. I take it that you wish these to be
formally offered as evidence.
Yes.
Mr. Smigiel, you saw the documents offered by the city. Do you
have objection to them being offered as evidence?
Well, I do in one sense. I don't know if this is out of order,
or what. But as far as Dr. Greenfeld's report. . . As I
recall the first job evaluation (description) the city sent
Dr. Greenfeld was for Park Maintenance Worker. As far as Dr.
Helgegar's report, my doctor, he also got a different type of
report.
We aren't arguing the validity of the documents. The case
1
2
3 Smig i e 1
Hentschke 4
5
6
7
a
9 Richardson
10
Hent schkql
12
Richardsok3
14
15 Smigiel
1E
’ 17
’ 1s
RichardsoE
21 Smi g ie 1
Richards&:
2:
24 Smigiel
Richards&
Smigiel 2~
25
2E
--
Pagt .8 of 23
is within the documents we are talking about, Do you have any
objections of their being offered in evidence as they were
submitted in a timely fashion?
Yes, I do have an objection. . .
I think his objection is to the why and not form of the document
itself. What he is arguing 5s evidently within the document. If
he has any objections to the form of ,. the document, that the docu-
ment was not accurate in terms of the document itself, that is
all we need here.
statement, you can accept the document into evidence and then
give evidence as to whether it is true or false.
These documents will be accepted into evidence unless there are
any objections from the floor.
Now, I think we ought to hear%r. Smigie1”s objections to the
evidence as contained in the report, which is what he was doing
before.
Yes, right, Mr. Smigiel, would you like to argue about the
evidence.
Well, number one, I would say. . . . Let me start with J. Faire
and Associates. That as far as Mr. Pieti states, that they
offered me rehabilitation through J. FAire and Associates, which
makes it sould like they came to me and said,”Hey, we’d like to
give you this rehabilitation.”
a lawyer for that. It took me from March. . . from February
until the time I got it to finally get rehabilitation.
Do you find anything in the report from J. Faire and Associates
that you do not agree is true?
No, I don’t think so.
Do you have any objections to any of the other documents or
do you have any argument with any of the other evidence that
has been given here.
Yes, the doctor’s reports.
All right. Please proceed.
As I started to say before, I. . As far as the doctor’s
reports went, Dr. Helgager received an inquiry as to what my
job classification was and if I could perform.the job.
Pieti’s office sent Dr. Helgager a questionnaire on park
maintenanceman, which I am not.
If you have objectibn to what is Mr. Greenfeldh
I fought for that. I had to get
Mr.
I wasn’t at the time, so his
1
2
3
4
Bates 5 Richardson
Bates 6
7
Pieti 9
10
11
12
13
14
RichardsoLE
Smigiel 1~
11
I€
1s
2c
21
2:
Watkins
22
2';
2E
-
Page -9 of 23
report bo me was false reporting.
Dr. -Greenfeld, I had brought this to Mr. Pieti's attention
a couple of times.
report anything about a street maintenanceman. I had found
something about a park maintenanceman,
Mr. Chairman, may I interject right here?
Certainly.
I'd like to ask Mr. Pieti a questidn.. Is there any particular
difference in the job description of a park maintenanceman and
the street maintenanceitizn insofar as the physical requirements
of the two positions?
I don't have a copy of the park maintenance worker class.
Maintenance Worker I is essentially the entry level for all manual
labor type classifications.
Worker I which is the basis for the J. Faire and Associates
evaluation to the point of including photographs of the equipment,
photographs of people working on streets.
minor differences, but off the top of my head, I can't recall
what they are.
Any further questions. Mr. Smigiel, do you have anything further?
I would like to state that as far as the job classifications of
park maintenanceman and street maintenanceman are concerned
there is approximately 80% difference in their job classifications
The classification of park maintenanceman said I could not remove
trees, I could not cut hedges, I could not cut wood, miscellaneous
things which have nothing to do with the street department, street
maintenance.
Mr. Smigiel. Mr. Chairman, May I? (Nod) Do you have any
evidence that, . . or some extenuating circunstance that you
were unable to subnit to this board to refute Mr. Greenfeld's
letter?
I don't believe I do right at this moment.
Mr. Smigiel it is very difficult for. . . at least for me, to
attempt to determine whether or not you had been properly
dismissed or terminated when you are unable to provide evidence
to this panel. The city has provided sworn testimony from some
four witnesses who have alleged that in a certain position
And the same thing with
I didn't find attached to either doctor's
May I ask a question?
I have a description for Maintenance
There may be some
I
I don't.
.. . . . . . . . . ..
1
2
3
4
5
6
7
Mitkevieh 8
9
Smigiel 10
11
Mitkevich 12 Smigiel
Mi tkevicd3
Smigiel 14
15 Mi tkevi ch
Smigiel 16
Mitkevichl?
18 Smigiel
Mi tkevi~d-~
Richardsm
21 Smigiel
Richards&
Smigiel 23
24 S, Spouse
25
26
Richardson 27
28
-
Page. 10 of 23
. . . It is my opinion that from your position you have
indicated feelings and thoughts on your part indicating some
objections on your part to certain statements made by your former
supervisors or Dr. Greenfeld's letter. But we have no evidence
that has been submitted by you that indicates that you can refute
the city's testimony and it makes it difficult for someone in
my position to say to you, ''I can evaluate -. the evidence you
submitted.", because you haven't, by :your own statement, you have,
no evidence to submit. That is all I have to say, Mr. Chairman.
I'd like to elaborate a little bit. Mr. Smigiel, you mentioned
I
that you anticipate another operation on your.knee. Are you
presently under the care of a doctor?
No, I'm not. I'm waiting for. . . I'm trying for the last six
months to. . .
Let me ask you, has an operation been recommended by a doctor?
No, it was in the beginning.
By what doctor?
I didn't want it at the time. Both doctors said that I most
probably would need another operation,
You've already had one operation, is that correct?
I've had two operations. One was major, one was minor.
In other words, this operation that you are anticipating is just
merely something that you think you might need?
Yes,
That's all.
Does the board wish to question any of the witnesses? Mr. Smigiel
do you have anything further to offer?
Just my statement.
Fine. We'll be happy to hear it.
I don't know if it's appropriate that my wife make a statement
about this.
I would like to speak for my husband at this time. I want to be
put in as a witness and I want it on the record that I want to
be put in as a witness since I have something. to offer.
All right. Do you solemnly swear to. . . Raise your right hand,
please.
give in this case will be the truth, the whole truth and nothing
but the truth, so help you God?
Do you solemnly swear that the evidence that you will
.,
S. Spouse
- - _- --.-__I ~
-
Page A of 23
I do. There seems to be some question about whether my husband
can drive a motor vehicle or not. That's one of the conditions
that the city says that they did terminate my husband for from
the City of Carlsbad. In front of .me I have a note from
Dr. Albertson--that is the doctor that had him on the medication--
I
l(
1:
1:
1:
11
It
Richards&
1:
1z
S.. Spouse
2€ Richards
s. SpousP
22
Richards 23 Smigiel
Richard&#
Pieti 25
Richard
Bates Yl
27
28
I
which says that he was unable to drive a motor vehicle. .Due
to a nervous breakdown, caused by the city,'which was provexi
because of everything that happened to my husband in the past
two years. He had to go into Mesa Vista Hospital. He spent
almost two months in the hospital under a doctor's care. He had
to be put on tranquilizers which prevented him from driving a
motor vehicle. Okay. Dr. Albertson gave me a note and I
submitted it to the City of Carlsbad: Okay. This is a note
stating that my husband is quite capable of operating a motor
vehicle. Okay. This is from the same doctor, Dr. Albertson.
NOW, I presented this to Mr. Pieti when my husband was up for
an in-house promotion for Sweeper Operator, which he was denied'
because of his disability.
This is what Mr. . . Is your name Mr. Bates? Is that what
you asked him for, proof of anything that he could. . .-
Mr. Bates was asking for proof that would refute anything in
Dr. Greenfeld's report.
Okay. Well, I want this into the record that my husband is
quite capable of doing some of the work that the city is saying
that he cannot do. He's quite capable of quite a few things.
We would be happy to accept that Mrs. Smigiel. Do you have
anything further to offer.
Well, I would like to stay here because I don't want my husband
to be over upset. The city has caused quite a bit of grief.
Mr. Smigiel, do you have anything further to offer.
No.
Mr. Pieti, do you have anything further to offer?
No, sir, I don't.
Any members of the board have anything further?
I have one question to Mrs. Smigiel. You indicated that there
is proof that the city has caused you% husband a nervous
breakdown. Is that proof that has been submitted at some other
time, or is it available for us now?
Okay. And' I gave them this paper.
28
-
Page ,,2 of 23
The doctor's reports. . .Do you mean, do I have the doctor's
reports stating that it is work related?
between the City of Carlsbad and a couple of doctors, Dr. Lyon
who is a psychiatrist and Dr. Albertson, another psychiatrist.
Both state that it is work related, that my husband did have
a breakdown.
This is being disputed
(The record will show sotto voce discussion among board members.)
The board will now be closed so that we can convene in private .
and reach our conclusions.
Mr. Chairman, are there to be closing statements?
Yes, thank you, Mr. Hentschke.
a closing statement?
(The record will show Mr. Smigiel asking Mrs. Smigiel to read
from his prepared statement.)
I do not feel it was a fair decision for the City of Carlsbad
to fire me.
it only fair'to my family and myself to try and make it brief.
In the city memorandum of 11/24/81, the subject of this hearing,
I will agree with one, three and four. As for number two, I
do not believe that my dismissal complied with state laws.
have filed charges with the California State Department of
Fair Employment and Housing.
matter I will not make any comments at this time.
Now, we can go to the following documents such as the city has
presented. I come here tonight feeling-that I am accused of
wrongdoing. As to number one, the report of Dr. Greenfeld--
that is the opinion df one doctor. 1 the basis of an opinion of one doctor can support the action
1 justified. : Thank you Mrs. Smigiel. Mr. Pieti.
Mr. Smigiel, do you wish to make
I was going to make a big issue of this, but I feel
I
Until there is a hearing on that
I do not know where or how
that the city has taken. The cause for my dismissal is not
You have heard the city's evidence and its witnesses and we
respectfully request that the board uphold the decision of the
City Manager.
Thank you.
deliberate .
(The record will show adjournment at 8:lO p.m. of five board
members and Attorney Hentschke to the Councilmatic Conference Room
Anything else from the board? We will adjourn to
Richardsod
2
3
4
5
‘6
7
8
9
10
11
12
13
14
15
16
11
- 1E
1s
2c
21
22
2:
24
25
2E
27
2E
-
Page 3 of 23
This- board will come to order.
(The record will show reconvene at 8:30 p,m.)
The Personnel Board after consideration of all the evidence and
argument finds that (a) Mr. Smigiel’ is unable to perform the
work required for classification of Maintenance Worker I and
(b) Mr. Smigiel presented no evidence indicating his ability
to perform the work required of a Maintenance r. Worker I and
(c) that the decision’ of City Manager to terminate the employ- .
ment of Mr. Smigiel be upheld.
The board is adjourned.
(The record will show adjournment at 8:35 p.m.’
.
/QAdJ/ Virginia Schuldt, Recording Secretary .
MEMORANDUM
DATE : November 24, 1981
TO : Chairman and Members of the Personnel Board
FROM : Personnel Director
SUBJECT: Board Hearing Scheduled for December 3, 1981
c.
In accordance with the provisions of Personnel Board Resolution No. 1, the following information in the appeal of WILLIAM SMIGIEL
to the Personnel Board is forwarded.
To preclude the introduction of irrelevant documents, the city is prepared to stipulate to several points.
1. That William Smigiel was discharged as an employee of the City of Carlsbad on October 22, 1981, by the City Manager.
That the dismissal complied with Personnel Rules of the City
of Carlsbad and existing state law.
2.
3. That Mr. Smigiel had sustained an industrial injury to his left knee on or about September 21, 1979.
4. That the above mentioned industrial injury resulted in a
finding of a permanent disability of 18% by the Workers' Compensation Appeals Board, decision Case No. 80SD6132, dated August 7, 1981.
The city hereby submits to the Personnel Board in support of arguments that will be made, the following documents.
1. Report of Richard Greenfield, M.D., dated March 10, 1981.
2. A report of J. Fair and Associates, employment and rehabili- tation consultants, dated February 23, 1981.
3. Statement of Roger W. Greer, Director of Utilities, dated
4. Statement of Don Brown, Street Maintenance Superintendent,
October 2, 1981.
dated October 2, 1981.
5. Statement of Chuck Mitchell, Street Maintenance Supervisor, dated October 1, 1981.
The city intends to call as witnesses the following persons.
1. Roger W. Greer, Director of Utilities, City of Carlsbad.
2. William C. Baldwin, Director of Maintenance, City of Carlsbad.
c
2
3, Don Brown, Street Maintenance Superintendent, City of Carlsbad.
4. Chuck Mitchell, Street Maintenance Supervisor, City of Carlsbad.
5. Robert D. Metcalf, a certified rehabilitation counselor with
J. Fair and Associates. .
P.
It is anticipated that all the aforemen'tioned witnesses will be
present at the time the board convenes and will be prepared to
be sworn as witnesses for the city in the Case of William Smigiel vs City of Carlsbad.
If the chairman and members of the board have any questions
regarding the attached documents or the witnesses the city intends to call, please call the Personnel Director at 438-5583.