HARSHBARGER, Justice:
Fred McDonald was a Brooke County deputy sheriff when Gary Young became sheriff on January 1, 1981. Young informed all his deputies that it was mandatory that they each be certified before July, 1983 by the Governor's Law Enforcement Training Subcommittee to have met the minimum level law enforcement officer qualifications.
Certification could be obtained through years of service, former training, or by completing a training program at...
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