Clean Energy for ME, LLC v. Maine Commission on Governmental Ethics and Election Practices

CourtSuperior Court of Maine
DecidedDecember 22, 2020
DocketCUMap-20-14
StatusUnpublished

This text of Clean Energy for ME, LLC v. Maine Commission on Governmental Ethics and Election Practices (Clean Energy for ME, LLC v. Maine Commission on Governmental Ethics and Election Practices) 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
Clean Energy for ME, LLC v. Maine Commission on Governmental Ethics and Election Practices, (Me. Super. Ct. 2020).

Opinion

I / WI) STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss CIVIL ACTION DOCKET NO. AP-20-14

CLEAN ENERGY FOR ME LLC,

Plaintiff V. ORDER

MAINE COMMISSION ON GOVERNMENTAL ETHICS AND ELECTION PRACTICES,

Defendant r-c and

CLEAN ENERGY MATTERS,

Party in Interest

On December 14, 2010 the court held a hearing over Zoom on the pending appeal and on

the motion by plaintiff Clean Energy for ME LLC for a stay. As set forth on the record and in the

court's order dated December 14, 2020, plaintiffs motion for a stay was denied.

With respect to the appeal, the initial question is whether the issue is properly before the

court. Plaintiff is appealing a May 22, 2020 order of the Commission on Governmental Ethics and

Election Practices to authorize its staff to investigate whether plaintiff (referred to in the record

and in its pleadings under a d/b/a of "Stop the Corridor" or "STC") qualified as a "ballot question

committee" within the meaning of21-A M.R.S. § 1056-B and was therefore required to file reports

pursuant to that section. (R. 185). 1 A "ballot question committee" is an entity that, although not

1 At the same time the Commission voted to seek an understanding of the broad range of STC's activities, to investigate STC's funding and reasons why its funding sources provided financial assistance to STC, and to require STC to provide unredacted documents. (R. 184-85). qualifying as a political action committee under 21-A M.R.S. § 1052(5), receives contributions or

makes expenditures in excess of $5,000 for the purpose of initiating or influencing a campaign

relating to a ballot question.

The Commission and party-in-interest Clean Energy Matters argue that this did not

constitute final agency action appealable under 5 M.R.S. § 11001(1) because the undertaking of

an investigation is a preliminary procedural action that is not independently reviewable. STC

responds that it may appeal now because review of a final agency determination as to whether it

constituted a ballot question committee would not provide an adequate remedy, citing the final

sentence of 5 M.R.S. § 11001(1). This argument is based on STC's contention that, before any

final decision is made, the Commission may pursuant to 21-A M.R.S. § 1003(3-A) disclose its

investigative working papers, including STC' s financial information, if those records are

"materially relevant" to a report by the Commission staff or a decision by the Commission. In that

case, STC argues, its information could be disclosed before there is a final agency action from

which it can appeal.

The statute does not contemplate broad disclosure but rather limited disclosure to the extent

materially relevant to a Commission decision or a staff report in connection with a Commission

decision. "Materially relevant" means not just relevant but sufficiently important to potentially

affect the outcome of a decision. See, e.g., Day's Auto Body, Inc. v. Town ofMedway, 2016 ME

121 16, 145 A.3d 1030. The record reflects that while some limited disclosure may be a theoretical

possibility under the statute, the practice of the Commission and the Commission staff is not to

make any such disclosure. Instead, disclosure would only occur after STC were found to be a ballot

question committee and ordered to file reports - a decision that would be a final agency action

subject to appeal before the reports were made public.

2 ( (

For that reason, the court concludes that the last sentence of 5 M.R.S. § 11001(1) does not

apply to this appeal. The decision of the Commission to undertake an investigation is not final

agency action subject to review. Otherwise parties subject to a potential investigation could stall

the investigation in its tracks while appealing the initiation of the investigation, undercutting the

purpose of the statute to provide timely financial disclosure information to the public from parties

seeking to initiate or influence a ballot question campaign.

In the alternative, assuming that STC's appeal is properly before the court, the decision of

the Commission is affirmed on the merits.

Pursuant to 21-A M.R.S. § 1003(1) the Commission "may undertake audits and

investigations to determine whether a person has violated [chapter 13 of Title 21-A]." Chapter 13

includes the registration and filing requirements for ballot question committees pursuant to 21-A

M.R.S. § 1056-B, and "person" is defined to include an organization. 21-A M.R.S. § 1001(3).

STC's argument is that the Commission did not have jurisdiction under § 1003(1) to

authorize an investigation of whether STC constituted a ballot question committee because it had

previously, in response to a complaint by party in interest Clean Energy Matters, undertaken an

investigation under 21-A M.R.S. § 1003(2) of whether STC qualified as a political action

committee. 2

The court can find absolutely no basis in the statute or in the public policy underlying the

statute to conclude that the Commission jurisdictionally handcuffed itself from exercising its

discretionary authority to commence a ballot question committee investigation by its previous

response to the request by Clean Energy Matters. Indeed, contrary to STC's position in this case,

2 Section I 003(2) provides that the Commission "shall" unde1take an investigation upon the request of any person when the requestor shows sufficient grounds for believing a violation has occun-ed.

3 the record demonstrates that c.ounsel for STC twice agreed that the Commission had the authority

to broaden its investigation. See March 10, 2020 Commission Meeting Tr. 33-34; May 22, 2020

Commission Meeting Tr. 50-51.

STC's final argument is that the Commission's investigation has been rendered moot and

must be terminated because of the Law Court's August 13, 2020 decision in Avangrid Networks

Inc. v. Secretary ofState, 2020 ME 109. That decision caused the citizen-initiated resolve to reject

the New England Clean Energy Connect Transmission Project to be removed from the ballot at

the past election. In support of its argument, STC argues that a Commission staff member was

reported in an online publication to have stated that the removal of the referendum question

eliminated the need for entities to register and report activities to influence the vote on that

referendum.

There are three problems with STC's argument. The first is that the statement by the

Commission staff member on which STC relies is not in the record, and the court cannot rely on

extra-record hearsay. The second is that the alleged statement by the Commission staff member is

not the Commission's position with respect to whether the ballot question committee investigation

investigation of STC has been rendered moot.

The third is that, even assuming that the removal of the citizen-initiated resolve meant that

after August 13, 2020 there was no longer a referendum campaign that a ballot question committee

could seek to influence, ballot question committees are defined as organizations that receive

contributions or make expenditures "for the purpose or initiating or influencing a campaign." 21­

A M.R.S. § 1056-B(l) (emphasis added). Therefore, if STC qualifies as a ballot question

4 (

committee, it should have registered and filed repo1is for time periods in which the signatures were

being gathered to "initiate" the campaign. 3

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Related

Day's Auto Body, Inc. v. Town of Medway
2016 ME 121 (Supreme Judicial Court of Maine, 2016)

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