Bangs v. Inhabs. of the Town of Wells

CourtSuperior Court of Maine
DecidedApril 1, 2002
DocketYORap-98-056
StatusUnpublished

This text of Bangs v. Inhabs. of the Town of Wells (Bangs v. Inhabs. of the Town of Wells) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bangs v. Inhabs. of the Town of Wells, (Me. Super. Ct. 2002).

Opinion

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STATE OF MAINE YORK, ss.

NORMAN BANGS AND BLUEBERRY RIDGE MOBILE VILLAGE, INC.,

Plaintiffs

Vv. ORDER ON PLAINTIFFS’ APPLICATION FOR AWARD OF ATTORNEY’S FEES

THE INHABITANTS OF THE TOWN OF WELLS, MAINE, THE ZONING

~ BOARD OF APPEALS OF SAID TOWN, AND BARBARA GAGNON, IN HER CAPACITY AS CODE ENFORCEMENT OFFICER OF SAID TOWN

Defendants

ORDER ON PLAINTIFFS’ APPLICATION FOR AWARD OF ATTORNEY'S FEES

The plaintiffs, Norman Bangs and Blueberry Ridge Mobile Village (collectively “Bangs” or “the plaintiffs”), filed an application requesting an award of

attorney’s fees and expenses pursuant to MLR. Civ. P. 54(b)(3) and 42 U.S.C. § 1988.

Upon review of the application, the opposition, and the relevant law, the application for attorney’s fees and costs will be denied.

BACKGROUND

Norman Bangs owns Blueberry Ridge Mobile Village (“Blueberry Ridge”), a

parcel of | land consisting of 51 mobile homes on 43 82 acres, and operated asa mobile home park.’ In 1989, after the Mobile Home Park Overlay District was created by the

Town of Wells (“Town”), Blueberry Ridge became a nonconforming use, but was grandfathered as a legally existing nonconforming use. In 1998, Norman Bangs submitted a proposal for expansion that contemplated adding 38 new sites to the existing mobile home park. A number of the new sites were included within the boundaries of the original 43.8 acre parcel of Blueberry Ridge. However, in order to meet the then-existing density requirements for a site built residential subdivision of 100,000 square feet per site (rather than mobile home park density requirements), the expansion proposal relied upon the annexation of two abutting parcels of land owned by Bangs.

The Town denied Bangs’ application. On appeal, the Zoning Board rejected Bangs’ contention that Blueberry Ridge was a non-conforming development, and concluded that Bangs’ proposed expansion effected substantial material changes to the original plan such that Blueberry Ridge would lose its grandfathered status and would be required to comply with current zoning, which loss would have precluded its existence as a mobile home park.

Bangs challenged the decision of the Zoning Board in an 80B appeal, and with

independent claims which raised the following issues: (1) whether the Wells Land

Use Ordinance (Chapter 138 of the Code of the Town of Wells) (“the Ordinance”) as

1 A mobile home park is defined as “a parcel of land under unified ownership approved by the municipality for the placement of 3 or more manufactured homes.” 30-A M.R.S.A. § 4358(1)(B); See also, Wells, Me., Code § 2 (May 11, 1997). The tenants “in a mobile home park rent the mobile home sites, place mobile homes which they own on the sites, and pay plaintiffs rent for the use of the land.

2 applied to the plaintiffs denied them equal protection under the federal and state constitutions; and (2) whether the Town failed to meet its obligations under 30-A M.R.S.A. § 4358(3)(M). Justice Brennan affirmed the decision of the Zoning Board as to the 80B appeal.

The independent claims were tried from November 1, 1999 to November 4, 1999. The court concluded that even if the Town’s Ordinance had not precluded mobile home parks outside of certain approved areas, Bangs’ application was not in compliance with the zoning regulations. Specifically, the court found that the proposed expansion plan would require encroachment on the reserved land, and would therefore change the Blueberry Ridge subdivision as originally approved; thus, the subdivision would lose the grandfathered density requirement. Because the plaintiffs’ expansion plan would have to be denied no matter what type of housing or what type of ownership scheme was proposed, the court held that the plaintiffs failed to show that they were treated differently than they would have been had this not been a mobile home park and had these not been mobile homes. The court went on to hold that even if there had been disparate treatment, the Town had a rational basis for such disparate treatment - i.e., the effect that the mobility of the living ‘units has on the size and shape of the mobile homes; and the effect that the type of ownership and tenancy have on the likelihood that the owner will make significant permanent improvements.

As to the applicable statute, 30-A M.R.S.A. § 4358(3)(M), the court concluded

that the Town had complied with the terms of the law because it had provided areas in which mobile home parks could be approved; and because it.had considered the request for expansion and denied the request on the ground that the proposed plan would be an expansion of a non-conforming use in violation of the Ordinance.

The plaintiffs appealed the determinations that the Ordinance did not violate the equal protection clauses of the United States and Maine Constitutions, and that the Ordinance did not violate 30-A M.R.S.A. § 4358. On appeal, the Law Court concluded that the Ordinance violated 30-A M.R.S.A. § 4358(3)(M) because it did not

permit the Town to give “reasonable consideration” to allow existing mobile home

parks to expand in their existing locations. Bangs v. Town of Wells, 2000 ME 186, { 17, 760 A.2d 632, 637. Having decided the plaintiffs’ appeal on statutory grounds, the - Law Court declined to reach Bangs’ constitutional claims. Bangs, 2000 ME 186, { 21 n.11, 760 A.2d at 638 n.11. Bangs now asserts an entitlement to attorney’s fees under 42 U.S.C. § 1988, as a prevailing party. DISCUSSION

L Attorney’s Fees Standard (42 U.S.C. § 1988)

Under 42 U.S.C. § 1988(b) (Supp. 2000): —

In any action or proceeding to enforce a provision of sections 1981,

1981a, 1982, 1983, 1985, and 1986 of this title, title IX of Public Law 92-318

... title VI of the Civil Rights Act of 1964 . . . or section 1981 of this title,

the court, in its discretion, may allow the prevailing party, other than the United States, a reasonable attorney’s fee as part of the costs ....

The United States Supreme Court has interpreted the word “may” to mean “must,”

unless special circumstances exist that would render an award unjust. Blanchard v.

Bergeron, 489 U.S. 87, 89 n.1 (1989). The plaintiffs are not foreclosed from obtaining attorney’s fees under section 1988 even though the Law Court declined to consider the constitutional issue on appeal. A party qualifies as a “prevailing party” if the actual relief on the merits of the party’s claim “materially alters the legal relationship between the parties by modifying the defendant’s behavior in a way that directly benefits the plaintiff.” Farrar v. Hobby, 506 U.S. 103, 112 (1992).

When a plaintiff recovers on the state rather than federal civil rights ground, the plaintiff must also show that (1) the federal civil rights claim is substantial enough to support federal jurisdiction, and (2) the statutory issue upon which the plaintiff prevailed arose from the same nucleus of common facts as the substantial federal claim to be considered a prevailing party. Maher v. Gagne, 448 U.S. 122, 133 n.15 (1980); Williams v.

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