CMC and Maintenance v. City of Bangor

CourtSuperior Court of Maine
DecidedAugust 15, 2006
DocketPENap-05-19
StatusUnpublished

This text of CMC and Maintenance v. City of Bangor (CMC and Maintenance v. City of Bangor) 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
CMC and Maintenance v. City of Bangor, (Me. Super. Ct. 2006).

Opinion

STATE OF MAINE SUPERIOR COURT PENOBSCOT, SS. CIVIL ACTION

CMC and Maintenance, Inc., Docket No. AP-05-19 jiii :-- I 1 , ;;l,;G NTEREDI ~ l ~ ~ bEg C O U R T SUPERIOR

Plaintiff AUG 18 2006 P E N O B S C O T COUNTY Order on Appeal

City of Bangor, Defendant

Pursuant to M.R.Civ.P. 80B,' CMC and Maintenance, Inc. (CMC) appeals from a decision issued by the City of Bangor City Council rejecting its bid for a custodial service contract and instead awarding that contract to River City Commercial Cleaning. The court has considered the parties' submissions on this appeal. CMC contends that the Council's decision awarding the contract to River City should be vacated because, it urges, two of the Council members who voted on the matter, Susan Hawes and Daniel Tremble, had a conflict of interest favorable to River City. A claim of administrative bias may be pursued either on the basis of the record of the administrative proceeding, as CMC has done here. However, when the factual basis of the bias claim rests on information extrinsic to the administrative record, the challenge must be developed by means of a trial of the facts in Superior Court pursuant to M.R.Civ.P. 80B(d). See also Baker's Table, Inc. v. City of Portland, 2000 ME 7 , 9 9,743 A.2d 237,240-41. Because CMC has not sought a trial of the facts, the resulting question is whether, as a matter of law, the record compelled the conclusion that the two Council

I The record submitted by the parties does not appear to include a provision of the City's ordinances that creates a right of appeal in this case to the Superior Court. Rule 80B itself does not create such a right, because it establishes the procedure for an administrative appeal when the right to such an appeal is established independently. Cf. Hodsdon v. Town of Hermon, 2000 ME 181, 9 3 , 7 6 0 A.2d 221,222 (appeal from decision of municipal planning board are authorized only if appellate rights are created by municipal ordinance). Nonetheless, the issue of appellate jurisdiction has not been raised, and so the court proceeds here with the assumption that such jurisdiction exists. members were disqualified from participation in the Council's award decision for the reason urged here by CMC, namely, the conflict of interest provisions of the City's ~rdinance.~ The record establishes that Tremble owns a business for whom the owner of River City performs accounting work and that Hawes, as she put it, has a similar relationship with River City's owner. Tremble and Hawes disclosed this circumstance to the Council during the meeting when it considered the custodial contract but prior to any substantive discussion or consideration of the matter. Tremble was also a member of the City's Finance Committee, which is a subcommittee of the Council itself. Prior to the Council's consideration of the contract award, the Finance Committee deliberated on the matter and recommended to the Council that the contract be awarded to River City, despite the staff's position that it should be awarded to CMC. Tremble participated in the Finance Committee's consideration of the issue, as did Hawes, although Hawes did not vote at the Finance Committee proceeding because she is not a member of that body. Neither Hawes nor Tremble disclosed their connection to River City at the time of the Finance Committee hearing because, as Tremble later noted at the full Council meeting, he did not realize then that there was even the question of a conflict. After Hawes and Tremble made their disclosures at the Council meeting and after the Council members elicited the view of the City's attorney, the remaining Council members voted unanimously that, under the conflict provisions of the City's ordinance, Hawes and Tremble were not disqualified from participating in the Council's consideration of the custodial services contract. That decision triggered the legislative obligations imposed on Hawes and Tremble to participate fully in the subsequent proceedings affecting the contract award. As he did at the Finance Committee level, Tremble voted in favor of awarding the contract to River City, and Hawes - now voting on the issue for the first time - did likewise. On this appeal, it is the Council's decision that Hawes and Tremble were not disqualified under the ordinance that is at issue. The court reviews that decision for any error of law, abuse of discretion or issuance of

2 In its complaint, CMC alleges that the contract awarded to River City is invalid because several provisions of state law barred Hawes and Tremble from participating in the Council's deliberations and voting. In its brief on appeal, CMC relies only on the conflict of interest provisions of the City's own ordinances. findings not supported by substantial evidence in the record. See Peregrine Developers, LLC v . Town of Orono, 2004 ME 95,g 8,854 A.2d 216,219. In two provisions, the City's ordinance defines the circumstances where a councilor is disqualified from participating in administrative matters. In other words, those circumstances set out in the ordinance establish the existence of a conflict of interest that bar a subject councilor from acting on or otherwise becoming involved in the matter. In pertinent part, the first such section provides: No. . .City Councilor. . .shall participate directly, by means of deliberations, approval or disapproval or recommendation, in the purchase of goods or services for the City and the award of any contracts with the City. . .where to his or her knowledge there is a financial interest, or special interest other than that possessed by the public generally, in such purchase or award held by:

(1) That individual. . .;

(2) A business in which that individual. . .serves as an officer, director, trustee, partner or employee in a supervisory or management position; or

(3) Any other person or business with whom or with which that individual . . .is in business. . . . City of Bangor, Maine, Code of Ethics, 3 33-6(A). To the extent relevant to this case, the ordinance defines a "financial interest," which a phrase used in section 33-6(A), as "[a] direct or indirect interest having monetary or pecuniary value, including but not limited to the ownership of shares of stock." Id., 3 33-2. Here, the record supports the conclusion that Hawes, Tremble and their businesses3 did not have a "financial interest" in River City. For a "financial interest" to exist, Hawes or Tremble would need to have a "direct or indirect [financial] interest" in River City, or such a relationship would have to exist between River City and a business for which the councilor serves in one of the capacities specified in section 33-6(A)(2). None of those circumstances exist. Rather, the owner of River City simply performs accounting work for Tremble's business and for either Hawes

As is noted in the text, the record is not entirely clear whether Hawes herself did business with the accounting firm conducted by River City's owner or whether she is affiliated with a business that has such a relationship with the accounting firm. Any such ambiguity in the record is not material to the dispositive analysis on this appeal. or her business. Such a relationship does not rise to the level of one that can be described as a "financial interest" within the meaning of the ordinance. Additionally, under section 33-6(A), Hawes or Tremble would be deemed to have a conflict of interest in the custodial services contract decision if either of them (or a business with which they were affiliated) had a "special interest" in the outcome of the decision. The ordinance defines "special interest" as [a] direct or indirect interest having value peculiar to a certain individual. . .

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Related

Baker's Table, Inc. v. City of Portland
2000 ME 7 (Supreme Judicial Court of Maine, 2000)
Hodsdon v. Town of Hermon
2000 ME 181 (Supreme Judicial Court of Maine, 2000)
Peregrine Developers, LLC v. Town of Orono
2004 ME 95 (Supreme Judicial Court of Maine, 2004)

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Bluebook (online)
CMC and Maintenance v. City of Bangor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cmc-and-maintenance-v-city-of-bangor-mesuperct-2006.