Bonnell v. State of Maine, Dep't of Human Servs.

CourtSuperior Court of Maine
DecidedJune 29, 2004
DocketCUMap-04-03
StatusUnpublished

This text of Bonnell v. State of Maine, Dep't of Human Servs. (Bonnell v. State of Maine, Dep't of Human Servs.) 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
Bonnell v. State of Maine, Dep't of Human Servs., (Me. Super. Ct. 2004).

Opinion

STATE OF MAINE < SUPERIOR COURT CUMBERLAND, ss. oes CIVIL ACTION ee DOCKET NO. AP-04-03 eeu 2S AT: 30. e CVA. (oe cee MICHAEL BONNELL, Petitioner V. ORDER ON RESPONDENT'S MOTION TO DISMISS AND STATE OF MAINE PETITIONER’S MOTION FOR DEPARTMENT OF TRIAL HUMAN SERVICES Respondent

“Que 20 204

This matter is before the court on the respondent’s motion to dismiss the

petitioner’s complaint for lack of subject matter jurisdiction pursuant to MLR. Civ. P. 12(h)(3) and failure to state a claim upon which relief may be granted pursuant to MLR. Civ. P. 12(b)(6); and on the petitioner’s motion for a trial pursuant to MLR. Civ. P. 80B(d). BACKGROUND

Michael Bonnell, the petitioner, is the parent of Lilly Bonnell, a minor child. On or about October 17, 2003, the Department of Human Services (“DHS”), through its Bureau of Child and Family Services, issued a “substantiation decision” stating that the petitioner was seen “backhanding his daughter, Lilly Bonnell” and had been “substantiated for physical abuse to Lilly Bonnell.” The petitioner requested a timely

review of the respondent’s substantiation decision. By a letter dated December 17, 2003, DHS notified the petitioner that it had reviewed its record of information and decided to uphold the substantiation decision.

The petitioner appeals to the court pursuant to MLR. Civ. P. 80B.' The petitioner’s complaint asserts that the respondent’s substantiation decision and the respondent’s decision upon review to uphold the substantiation decision were judicial or quasi- judicial acts. He further asserts that the substantiation decision was unsupported by substantial evidence on the whole record and was arbitrary and capricious. In addition, the petitioner argues that the respondent’s substantiation decision was reached in violation of the petitioner’s right to due process in that the respondent acted without affording the petitioner the opportunity for a hearing and trial of the facts and the respondent acted without sufficient investigation and reliable evidence of the incident involving Lilly Bonnell.

After the petitioner filed his complaint with the court, the respondent filed its motion to dismiss and the petitioner filed his motion for trial. While the parties dispute whether the action should be dismissed, they agree that if the court finds it has jurisdiction over this case, a trial to introduce evidence would be appropriate because DHS’s substantiation decision was made under circumstances that did not allow for a record to be made.

DISCUSSION

I. Subject Matter Jurisdiction Under M.R. Civ. P. 12(h)(3)

"Jurisdiction is the essential basis upon which all court powers rest, and even

willing submission by the parties of their dispute cannot confer it." Fletcher v. Feeney,

‘ At the April 28, 2004 hearing on this matter, the petitioner agreed to the dismissal of Count II, which had been brought pursuant to Rule 80C.

2 400 A.2d 1084, 1089 (Me. 1979). When a trial court lacks jurisdiction, the absence of jurisdiction is noticed, and the case proceeds no further. Id. (citing M.R. Civ. P. 12(h)(3)).

In the present action, subject matter jurisdiction under M.R. Civ. P. 80B is at issue. The rule provides: "When review by the Superior Court, whether by appeal or otherwise, of any action or failure or refusal to act by a governmental agency, including any department, board, commission, or officer, is provided by statute or is otherwise available by law, proceedings for such review shall .. . be governed by these Rules of Civil Procedure as modified by this rule." M.R. Civ. P. 80B.

"Otherwise available by law’ refers to review of an action that could have been

had by means of a common law writ.” Waterville Homes, Inc. v. Mun. Officers of

Waterville, 589 A.2d 458, 459 (quoting Lyons v. Bd. of Dir. of Sch. Admin. Dist. No. 43,

503 A.2d 233, 236 (Me. 1986)). Where a state agency acts in a judicial or a quasi-judicial

capacity, its actions may be reviewed under a writ of certiorari. Carter v. Wilkens, 160

Me. 290, 294 203 A.2d 682, 684 (1964).’

In the present case, the court has subject matter jurisdiction under 80B because DHS’s substantiation decision was quasi-judicial in nature® and impacts the petitioner’s due process rights. Given the likelihood that DHS’s substantiation decision will negatively impact the petitioner's ability to obtain employment in any field involving

children, the petitioner’s liberty interest is at issue. See 22 M.R.S.A. § 4008(3)(F) (2003)

* An agency acts in a quasi-judicial capacity when it adjudicates the rights of a party. Cf. Irish v. Gimbel 1997 ME 50, { 15, 691 A.2d 664, 672 (holding that a screening panel was not a quasi-judicial tribunal because it has no power to adjudicate the rights of any of the parties before it).

* The procedures used to make a substantiation decision are much like those used to make a judicial decision. In making a substantiation decision, caseworkers are guided by formal substantiation practice guidelines. See Bureau of Child and Family Services, Substantiation Practice Guidelines (found at http:/ /www.state.me.us/dhs/bcfs/ policy /sect04/ iv_d_l_substantiation_practice_guidelines.htm) (last visited June 28, 2004). In addition, the substantiation decision is based on a “preponderance of the evidence” test. See Bureau of Child and Family Services, Child Protection (found at www.maine.gov/dhs/bcfs/ protection. htm (last visited June 28, 2004).

(requiring DHS to disclose relevant information in the records to the Commissioner of Education when the information concerns teachers, other professional personnel issued certificates under Title 20-A, any persons employed by schools approved pursuant to

Title 20-A, or any employees of schools operated by the Department of Education); see

also Board of Regents v. Roth, 408 U.S. 564, 572 (1972) (holding “[w]ithout doubt, [liberty] denotes not merely freedom from bodily restraint but also the right of the individual to contract, to engage in any of the common occupations of life... “)

(quoting Meyer v. Nebraska, 262 U.S. 390, 399) (1923)); cf. In re Application of Feingold,

296 A.2d 492, 498-99 (Me. 1972) (holding “[a] State cannot exclude a person from the practice of law or from any other occupation in a manner or for reasons that contravene the Due Process or Equal Protection Clause of the Fourteenth Amendment") (quoting

Schware v. Board of Bar Examiners, 353 U.S. 232, 238-239 (1957)).

The respondent cites Paul v. Davis, 424 U.S. 693 (1973) for the proposition that

stigma to one’s reputation that may seriously impair future employment opportunities

does not amount to a deprivation of one’s liberty interests. Paul v. Davis, 424 U.S. 693

(1973) (holding that where police officers included the respondent's name in a police flyer of “active shoplifters,” the respondent was not deprived of his “liberty” interests).

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Related

Meyer v. Nebraska
262 U.S. 390 (Supreme Court, 1923)
Joint Anti-Fascist Refugee Committee v. McGrath
341 U.S. 123 (Supreme Court, 1951)
Wieman v. Updegraff
344 U.S. 183 (Supreme Court, 1952)
Schware v. Board of Bar Examiners of NM
353 U.S. 232 (Supreme Court, 1957)
Board of Regents of State Colleges v. Roth
408 U.S. 564 (Supreme Court, 1972)
Paul v. Davis
424 U.S. 693 (Supreme Court, 1976)
Baker's Table, Inc. v. City of Portland
2000 ME 7 (Supreme Judicial Court of Maine, 2000)
Moody v. State Liquor & Lottery Commission
2004 ME 20 (Supreme Judicial Court of Maine, 2004)
Fletcher v. Feeney
400 A.2d 1084 (Supreme Judicial Court of Maine, 1979)
Lyons v. Board of Directors
503 A.2d 233 (Supreme Judicial Court of Maine, 1986)
McAfee v. Cole
637 A.2d 463 (Supreme Judicial Court of Maine, 1994)
Carter v. Wilkins
203 A.2d 682 (Supreme Judicial Court of Maine, 1964)
Hall v. Board of Environmental Protection
498 A.2d 260 (Supreme Judicial Court of Maine, 1985)
Palesky v. Secretary of State
1998 ME 103 (Supreme Judicial Court of Maine, 1998)
Irish v. Gimbel
1997 ME 50 (Supreme Judicial Court of Maine, 1997)
Application of Feingold
296 A.2d 492 (Supreme Judicial Court of Maine, 1972)
Waterville Homes, Inc. v. Municipal Officers of Waterville
589 A.2d 458 (Supreme Judicial Court of Maine, 1991)

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