Oakes v. West Virginia Department of Finance and Administration

In Oakes v. West Virginia Department of Finance and Administration, 164 W. Va. 384, 264 S.E.2d 151 (1980), the employee was terminated from his tenured civil service position as a postmaster for the state capitol post office. The employee was fired because he allegedly was negligent in failing to ensure two pieces of registered mail, containing bid proposals for financing the state's purchase of an airplane, were delivered before the closing deadline for such bid. The Court held that "good cause" was not shown to justify terminating the employee. In Syllabus point 1 of Oakes the Court stated, in part, that good cause "means misconduct of a substantial nature directly affecting the rights and interest of the public, rather than . . . trivial or inconsequential matters, or mere technical violations of statute or official duty without wrongful intention." 164 W. Va. 384, 264 S.E.2d 151. The decision in Oakes was based in part upon the fact "that nothing in the record indicated that Mr. Oakes had a prior history of negligent or inefficient conduct in his supervision of the Capitol Post Office, nor that he had received any reprimands or been subjected to any disciplinary proceedings." Oakes, 164 W. Va. at 386, 264 S.E.2d at 153. In sum, an employee had been terminated from his civil service position as postmaster for the state capitol post office for negligent mail handling. This Court held that "good cause" had not been demonstrated to justify the termination. 164 W. Va. at 389, 264 S.E.2d at 154. The Court explained that "nothing in the record indicated that Mr. Oakes had a prior history of negligent or inefficient conduct in his supervision of the Capitol Post Office, nor that he had received any reprimands or been subjected to any disciplinary proceedings." 164 W. Va. at 387, 264 S.E.2d at 153. The Court explained as follows regarding the termination of a state employee: "W.Va.Code, 29-6-15, requires that the dismissal of a civil service employee be for good cause, which means misconduct of a substantial nature directly affecting the rights and interest of the public, rather than upon trivial or inconsequential matters, or mere technical violations of statute or official duty without wrongful intention."