TC's reversal of AHRC's determination of discrimination was in error due to incomplete record and lack of witness testimony

UNPUBLISHED

Appellant-Respondent Alfred Dartis appeals the trial court’s judgment granting a petition for judicial review brought by Appellee-Petitioner Delco Remy America, Inc. ("DRA") and reversing the finding of the Anderson Human Relations Commission ("AHRC") that DRA’s termination of Dartis’s employment was due to unlawful discriminatory practices. Upon appeal, Dartis claims that the trial court erred in concluding that the AHRC’s finding was not supported by substantial evidence and was contrary to law.

Conclusion (slip op. at 9): Because both parties agree, and the trial court found, that the AHRC hearing was invalid for lack of a quorum, we reverse the trial court’s judgment in favor of DRA and remand to the trial court with instructions to remand this cause to the AHRC for a new hearing with a sufficient quorum.

Key Analysis (slip op. at 9): The trial court’s judgment is based upon an incomplete record missing an unknown amount of witness testimony which may or may not have supported Dartis’s claim. Its reversal of the AHRC’s determination of discrimination was therefore in error.