Duchaine v. Town of Gorham

CourtSuperior Court of Maine
DecidedJune 15, 2001
DocketCUMcv-99-573
StatusUnpublished

This text of Duchaine v. Town of Gorham (Duchaine v. Town of Gorham) 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
Duchaine v. Town of Gorham, (Me. Super. Ct. 2001).

Opinion

STATEOFMAINE SUPERIOR COURT

CUMBERLAND, ss. Soe ts CIVIL ACTION _ DOCKET NO. CV-99-573 SUSAN DUCHAINE, DANA'H. 3 57 fit ‘gj! Pr. Cy © Of) :

LAMPRON, JAMES E. SHAW, JR., THOMAS P. SHAW, DESIGN DWELLINGS, INC., and SOLD, INC., Plaintiffs Vv. DECISION AND ORDER THE TOWN OF GORHAM,

Defendant

FACTUAL BACKGROUND

Plaintiffs Susan Duchaine, Dana Lampron, James Shaw and Thomas Shaw (collectively referred to as the “Individual Plaintiffs”) are the joint owners of Corporate Plaintiff SoLD, Inc., a Maine Subchapter S corporation engaged in land acquisition and development. Defendant's Statement of Material Facts (“DSMF”) 1; Plaintiffs’ Opposing Statement of Material Facts (“POSMF”) { 1. Duchaine is also the President, Treasurer and sole shareholder of Corporate Plaintiff Design Dwellings, Inc., a Maine Subchapter S corporation engaged in building and development. DSMF { 2; POSMF 2.

On May 26, 1998, the Plaintiffs filed a notice of claim pursuant to the Maine Tort Claims Act, listing the alleged difficulties the Plaintiffs have experienced with Defendant Town of Gorham’s Planning Department “[d]uring the past couple of years.” DSMF 4 14. The Town of Gorham was insured under an insurance policy

providing limited liability coverage by National Union Fire Insurance Company of

Pittsburgh, Pennsylvania, during the relevant time period. Id. { 46. The Plaintiffs subsequently filed a nine-count complaint alleging denial of the right to equal protection (Count I), denial of the right to substantive due process (Count II), denial of the right to freedom of speech (Count III), denial of the right to petition for redress of grievances (Count IV), denial of procedural due process (Count V), negligence (Count VI), injurious falsehood (Count VII), defamation (Count VIID, and false light (Count IX). The injurious falsehood/slander of title claim is advanced only with regard to the Forest Estates subdivision project and concerns events that occurred in 1994. Id. q 45.

Originally, the complaint alleged violations of the United States and Maine Constitutions. Id. 9 47. After the Town exercised its right to have the case removed to federal court, the Plaintiffs moved to amend the complaint to remove all federal claims and remand the case to state court. Id. All federal claims were subsequently dismissed with prejudice by the United States District Court for the District of Maine and the case was remanded. The Town now seeks summary judgment on the Plaintiffs’ amended complaint. For the following reasons, the Town’s motion is granted.

DISCUSSION

I. Standing The concept of standing to sue means that the plaintiff has a sufficient a personal stake in the controversy to obtain a judicial resolution of that controversy.

Halfway House, Inc. v. City of Portland, 670 A.2d 1377, 1379 (Me. 1996). The

Individual Plaintiffs may not assert the rights of their corporations, but must instead

Nw demonstrate that they have received some particularized injury to have standing to

raise the claims. See Stull v. First Am. Title Ins. Co., 2000 ME 21, 9 11, 745 A.2d 975,

979. The particularized injury requirement is met “when the defendant's actions — have adversely and directly affected the plaintiffs property, pecuniary or personal rights.” Id.

The Individual Plaintiffs argue that they have standing to assert the constitutional claims because they are owners of the Corporate Plaintiffs and made personal payments to the corporations which were then used to pay expenses such as the alleged excessive attorney’s and engineering fees. The Individual Plaintiffs’ positions as shareholders do not override the requirement that they sustain

particularized injury. See Jones v. Niagara Frontier Trans. Authority, 836 F.2d 731,

736 (2d Cir. 1987) (“A shareholder--even the sole shareholder--does not have standing to assert claims alleging wrongs to the corporation.”); Stull, 2000 ME 21, 4 11, 745 A.2d at 979 (holding that sole shareholder did not have standing to maintain a suit seeking recovery for the breach of an insurance contract between his corporation and defendant insurance company because the shareholder failed to demonstrate particularized injury). While the Individual Plaintiffs did make personal payments to the corporations, the Town’s conduct did not directly affect their personal pecuniary interest as required to demonstrate a particularized injury. The Individual Plaintiffs therefore do not have standing to pursue the constitutional, negligence or slander of title claims.

The Town also argues that the Individual Plaintiffs lack standing to pursue the defamation and false light claims because the evidence supporting the alleged damage to their reputations is conjecture and surmise. The Individual Plaintiffs have standing to assert those claims as damage to reputation is a particularized injury within the meaning of the term. IL Constitutional Claims

The Maine Civil Rights Act (“MCRA”), 5 M.R.S.A. §§ 4681-4685 (Pamph. 2000), is the sole vehicle by which a plaintiff may bring a claim alleging a violation

of the Maine Constitution. Andrews v. Dep’t of Env. Protection, 1998 ME 198, ] 23,

716 A.2d 212, 220. Pursuant to the MCRA:

Whenever any person, whether or not acting under color of law, intentionally interferes or attempts to intentionally interfere by physical force or violence against a person, damage or destruction of property or trespass on property or by the threat [thereof] ... with the exercise or enjoyment by any other person of rights secured by .. . the Constitution of Maine... , the person whose exercise or enjoyment of these rights has been interfered with, or attempted to be interfered with, may institute and prosecute in that person’s own name and on that person’s own behalf a civil action for legal or equitable relief.

3 M.R.S.A. § 4682 (emphasis added). In Andrews, the plaintiff alleged a violation of his free speech rights and sought monetary, declaratory and injunctive relief pursuant to article I, section 4 of

the Maine Constitution. Andrews, 1998 ME 198, § 21, 716 A.2d at 220. The Law

Court held that the plaintiff’s failure to allege an interference with his rights by “physical force or violence, damage or destruction of property, trespass on property, or threats thereof” was fatal to his constitutional claim. Id. { 23. Similar to the

plaintiff in Andrews, the Plaintiffs’ statement of material facts is completely devoid of any facts that would establish this necessary predicate under the MCRA.

Relying on a sentence in Andrews that the Law Court was “declin[ing] to expand the available remedies for a violation of rights guaranteed by the Maine Constitution beyond those which the Legislature in its wisdom has provided,” the Plaintiffs argue that the Law Court did not intend to construe the MCRA to be the exclusive remedy for all violations of the Maine Constitution. Seeid. The Law Court made this statement after noting that the plaintiff failed to establish the necessary predicate for a MCRA claim, however. Id. Taken in context, it is apparent the Law Court was rejecting the plaintiff's argument to expand the remedies available under the MCRA to allow a private cause of action for claims that have not alleged an interference by physical force or violence, damage or destruction of property, or trespass.

The Plaintiffs suggest that although the MCRA may be the exclusive means of obtaining monetary damages for state constitutional violations, it does not purport to foreclose injunctive, declaratory or any other non-monetary relief for such violations.

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Duchaine v. Town of Gorham, Counsel Stack Legal Research, https://law.counselstack.com/opinion/duchaine-v-town-of-gorham-mesuperct-2001.