Conservation Law Found., Inc. v. Town of Lincolnville

CourtSuperior Court of Maine
DecidedJune 27, 2001
DocketWALap-00-3
StatusUnpublished

This text of Conservation Law Found., Inc. v. Town of Lincolnville (Conservation Law Found., Inc. v. Town of Lincolnville) 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
Conservation Law Found., Inc. v. Town of Lincolnville, (Me. Super. Ct. 2001).

Opinion

STATE OF MAINE SUPERIOR COURT

WALDO, SS. Docket No. AP-00-3 La = are ape [deol Conservation Law Foundation, Inc. et al. STATE OF MAINE

Waldo County Superis; Court

Vv. ORDER Fe8 28 2801,

REC'D AND FILED

Town of Lincolnville et al. Joyce M. Page, Clerk

Pending before the court is the motion for summary judgment filed by defendants James Munroe and Richard Nightingale (collectively, "Munroe"). In his motion, Munroe contends that, as a matter of law, neither plaintiff has standing to pursue their appeal from a decision of the Lincolnville Planning Board, approving the movants' application for a proposed subdivision on Route 1 in Lincolnville.!

A. Procedural posture of motion for summary judgment

None of the parties’ submissions on the pending motion satisfies the requirements of M.R.Civ.P. 7(d) and 56. Munroe's rule 7(d) statement of material fact merely incorporates by reference interrogatory answers submitted by each of the two plaintiffs. His statement of material fact thus falls short of the requirement governing the contents of such a filing. Further, the plaintiffs’ submission does not even include a statement of

material fact, despite the clear requirements of the rules governing

1The movants had also filed a motion for trial on the facts. See M.R.Civ.P.

80B(c). The issue that Munroe seeks to try is whether the plaintiffs have standing to bring this appeal under M.R.Civ.P. 80B. At oral argument on the motion for summary judgment, however, Munroe withdrew his motion for that trial. Thus, the summary

judgment motion alone remains pending. summary judgment motion practice. Rather, the plaintiffs have attempted to supplement the record on summary judgment with an affidavit of their | attorney, to which is appended a lengthy document relating to the nature and purposes of plaintiff Conservation Law Foundation, Inc. ("CLF").

Despite these procedural shortcomings, the court will proceed to a consideration of the merits of the motion. Neither party contests the other's formulation of the evidence, and Munroe has withdrawn his motion for trial of the facts pertinent to the plaintiffs’ standing. Consequently, in combined effect, the parties have submitted the standing issue on a stipulated record. Ordinarily, a decision on the question of standing is considered as part of the final decision on the merits of the appeal. See,

e.g.. Rowe v. City of South Portland, 1999 ME 81, 730 A.2d 673.

Submission of the standing issue alone thus represents a de facto bifurcation of that question from the merits, Neither party has challenged this approach as part of the pending motion.* Thus, in this order, the court will address the question of whether, on this factual record, the plaintiffs have standing to pursue their rule 80B appeal.

Additionally, although the parties did not raise the issue, Munroe's motion requires consideration of whether, as part of a rule 80B appeal, it is proper for the parties to present evidence on the question of standing. Here, Munroe does not seek to present evidence in support of an

independent claim for relief, (Indeed, Munroe is the appellee in this

proceeding.) See Baker's Table. Inc. v. City of Portland, 2000 ME 7, { 9, 743

2In their objection to the now-withdrawn motion for trial of the facts, the

plaintiffs did not oppose the concept of establishing some type of record that would

allow the development of facts, although they advocated an alternative to a conventional trial. A.2d 237, 240-41. However, "subsidiary claims" to an appeal are subject to evidential development in the Superior Court. Id.; see, e.g., Boisvert_v. King, 618 A.2d 211, 214 (Me. 1992) (a trial on the facts was permitted on the timeliness of an appeal).

In order to establish standing to challenge municipal action in court, the appellant "must have participated in the hearing and must demonstrate a particularized injury caused by" the municipality's decision.

Rowe v. City of South Portland, 1999 ME 81, J 3, 730 A.2d 673, 674. While

an appellant's participation in the administrative proceeding is generally revealed by a conventional record on appeal, that party's particularized injury may not be apparent from the record. Here, for example, under the Town's ordinance, a member of the public did not have to establish “particularized injury" in order to participate in the municipal proceeding. Rather, it appears that the Board's hearing was open to any member of the public. See TOWN OF LINCOLNVILLE SUBDIVISION ORDINANCE § IV(A) (1999). Thus, the factual basis for a party's standing need not appear in the record, and it therefore appears to be a proper area for evidential development in the Superior Court.

Summary judgment motions and fact-grounded adjudications are not appropriate vehicles for the resolution of issues on appeal. Martin v. Unemployment Insurance Commission, 1998 ME 271, § 10, 723 A.2d 412, 416. In the case at bar, however, Munroe's challenge to the plaintiff's standing requires the court to act in two capacities: as a fact-finder to determine, as a factual matter, whether the plaintiffs do have standing to pursue this challenge to the Town's decision; and, if the plaintiffs have

standing, as an appellate entity to review the municipality's action. To the extent that the parties call on the court to determine the question of standing, the procedures associated with its fact-finding role -- including the summary judgment motion practice -- should be available.

B. Record on summary judgment

Plaintiff Christopher W. Osgood ("Osgood") has been a resident of Lincolnville since 1974. Osgood's property does not abut the Munroe parcel that is the subject of the proposed subdivision. Between 1985 and 1987, he was a member of the "Lincolnville Route 1 Citizens' Committee,” which was a group of residents who lived on Route 1 in Lincolnville. That committee "provided input" to the Maine Department of Transportation regarding the state's plans to reconstruct that road. Osgood also participated in a "Local Action Committee" comprised of residents of nearby municipalities, which addressed issues also relating to Route 1. Beginning in 1995, he served on a formal municipal committee (the "Lincolnville Route 1 Committee"), established under the Town's ordinances, that was responsible for working with local residents and governmental representatives in designing the Route 1 corridor through Lincolnville. The committee's work included “particular focus" on maintaining the Town's scenic and historical qualities. At least in part as a result of the committee's work, agencies responsible for the redesign of Route 1 deviated from their standard model to accommodate "the unique and outstanding visual aspects" of the Munroe property. The Town created access to allow pedestrians, bicyclists and motorists to "enjoy the scenic qualities" created by the parcel.

Osgood has been a member of the municipal committee responsible

for the promulgation of a comprehensive plan. In that capacity, his duties included the creation of an inventory and map of "scenic assets” in the Town, to allow those areas particular treatment and protection in the Towns’ zoning ordinances. The Munroe property was identified and included as one of those assets.

Osgood was a member of the Town's Land Use Committee between 1993 and 2000. Among other things, that committee proposed ordinances that assisted governmental agencies in their roadway design approach noted above.

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