Dunn v. Bellows

Superior Court of Maine·Decided March 7, 2023·No. KENap-23-07·Unpublished

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC, ss. CIVIL ACTION Docket No. AP-23-07

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WILLIAM H. DUNN, JR.,

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Petitioner,

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v.

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SHENNA BELLOWS, in her official

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capacity as Secretary of State for the DECISION AND ORDER

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State of Maine,

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Respondent,

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and, Se9 ee=

NO BLANK CHECKS BALLOT Nee

QUESTION COMMITTEE, ee Nee Nome

Intervenor.

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Introduction

Petitioner William H. Dunn, Jr. (<Petitioner=) has filed an action pursuant to 21-A M.R.S. § 905(2) and M.R. Civ. P. 80C appealing Secretary of State Shenna Bellows9 Determination of the Validity of a Petition for Initiated Legislation, dated January 26, 2023. In her decision, the Secretary of State (<the Secretary=) found that the citizen initiative petition at issue4known as <An Act to Require Voter Approval of Certain Borrowing by Government-Controlled Entities and Utilities and to Provide Voters More Information Regarding that Borrowing= 4was valid and supported by a sufficient number of valid signatures. More particularly, the Secretary found that the proponents of the initiative submitted 68,807 valid signatures, 1,125 above the 67,682 threshold.

On appeal, Petitioner argues that the Secretary erroneously deemed at least 1,181 of those signatures to be valid, and when removed from the final signature count, a deficit of

56 signatures exists.' Among the errors alleged, Petitioner contends that the Secretary failed to comply with the statutory requirements governing circulator affidavits, as set forth in 21-A M.R.S. § 903-A(4). For relief, Petitioner asks the court to remand the matter to the Secretary for invalidation of the challenged signatures or to directly reverse the Secretary9s decision.

By statute, the court is required to decide this appeal <before the 40th day after the decision of the Secretary of State.= 21-A M.R.S. § 905(2). The court has reviewed the record as well as the briefing submitted by Petitioner, the Secretary, and Intervenor No Blank Checks Ballot Question Committee. Oral argument was held on March 3, 2023.

Background

By way of some brief background,= William Ritch-Smith filed an Application for Citizen9s Initiative with the Secretary on September 7, 2021. On December 7, 2021, the

Secretary approved the form of the petition, and supporters of the initiative thereafter began collecting signatures. As part of that process, the individuals who solicited signatures for the petition4i.e., the circulators 4prepared <circulator affidavits= to be submitted to the Secretary along with the other petition materials. Circulator affidavits must meet certain statutory requirements, including those described in 21-A M.R.S. § 903-A(4).

On December 27, 2022, the campaign submitted to the Secretary 28,238 petitions containing 93,837 signatures. The Secretary then proceeded to review the petitions over a period of 30 days. On January 26, 2023, the Secretary issued her Determination of the Validity of the Petition for Initiated Legislation. In her written Determination, the Secretary

' Petitioner originally challenged 1,184 signatures. This number changed after Petitioner acknowledged various signatures that were erroneously included in the challenged signature tally and identified additional signatures that were subject to challenge.

2 Given the truncated timeframe for issuing a decision, the court dispenses with a lengthy factual and procedural background.

invalidated 25,030 signatures, 28 of which were deemed <invalid because the circulator did not file a circulator9s affidavit at the time the petitions were filed with the Secretary of State or the affidavit was not properly completed.= The Secretary nevertheless found 68,807 valid signatures, a total that exceeded the constitutional threshold by 1,125. See Me. Const. art IV, pt. 3, § 18(2). Accordingly, the Secretary found the petition to be valid. On February 6, 2023, Petitioner appealed the Secretary9s decision pursuant to M.R. Civ. P. 80C and 21-A M.R.S. § 905(2).

Standard of Review/Legal Framework

The court9s discussion must begin with recognizing the various constitutional rights and principles implicated in this case. The Maine Constitution grants Maine people the right to legislate by direct initiative. Me. Const. art IV, pt. 3, § 18. The Law Court has stressed the importance of such a right, declaring <the right of the people to initiate and seek to enact legislation [to be] an absolute right.= McGee v. Sec'y of State, 2006 ME 50, 4 21, 896 A.2d 933. <[A]lthough the Legislature has the authority to enact laws providing for the implementation of the initiative right, any legislative implementation must respect the substance of the constitutional right.= Jd. | 20; Me. Const. art IV, pt. 3, § 22. The right cannot be abridged either directly or indirectly by governmental action. McGee, 2006 ME 50, 4 21, 896 A.2d 933. Accordingly, laws governing the direct initiative process <must be liberally construed to facilitate, rather than handicap, the people9s exercise of their sovereign power to legislate.= Allen v. Quinn, 459 A.2d 1098, 1102-03 (Me. 1983).

The Law Court has also recognized that <[t]he circulation of direct initiative petitions is 8core political speech,9 and any state regulation of the initiative process must be 8narrowly tailored9 to carry out a compelling state purpose.= Me. Taxpayers Action Network v. Sec'y of State, 2002 ME 64, 4 8, 795 A.2d 75. Laws governing the initiative process should therefore be construed in a way that avoids imposing an impermissible burden on protected speech. See id.; see also State v. Cropley, 544 A.2d 302, 304 (Me. 1988).

Moreover, under the Maine Constitution, <[t]he Secretary of State is the constitutional officer entrusted with administering4and having expertise in4the laws pertaining to the direct initiative process.= Reed v. Sec'y of State, 2020 ME 57, ¥ 18, 232 A.3d 202. The Secretary has been granted plenary power to investigate and determine the validity of petitions. Me. Taxpayers Action Network, 2002 ME 64, § 12 n.8, 795 A.2d 75.

When assessing the Secretary9s determination of initiative petitions, the Court's review must be deferential and limited, keeping in mind the Secretary9s <broad[] authority= in the context of evaluating referendum petitions. Knutson v. Dep't of Sec'y of State, 2008 ME 124, 720 n.7, 954 A.2d 1054; Passadumkeag Mountain Friends v. Bd. of Envtl. Prot., 2014 ME 116, § 12, 102 A.3d 1181.

By statute, an action seeking review of the Secretary9s decision on a direct initiative petition <must be conducted in accordance with the Maine Rules of Civil Procedure, Rule

80C, except as modified by this section.= 21-A M.R.S. § 905(2). In Palesky v. Sec9y of State, the Law Court held that <[t]he provisions of section 905 that could be deemed 8modifications9 of Rule 80C relate to the expedited timing of the appeal.= 1998 ME 103, 4 5, 711 A.2d 129. The Palesky court further concluded that 21-A M.R.S. § 905 does not require <a full de novo trial=; rather, the procedural framework for a Section 905 appeal is set forth in Rule 80C. Jd. J¥ 5-6, 8.

Under Rule 80C, the court is not permitted to overturn an agency9s decision <unless it: violates the Constitution or statutes; exceeds the agency9s authority; is procedurally unlawful; is arbitrary or capricious; constitutes an abuse of discretion; is affected by bias

or error of law; or is unsupported by the evidence in the record.= Kroger v. Dep9t of Envtl. Prot., 2005 ME 50, 7, 870 A.2d 566; 5 M.R.S. § 11007(4). The party seeking to vacate a state agency decision has the burden of persuasion on appeal. Anderson v. Me. Pub. Emp. Ret. Sys., 2009 ME 134, 43, 985 A.2d 501.

When reviewing agency decisions, the court must examine <<8the entire record to determine whether, on the basis of all the testimony and exhibits before it, the agency could fairly and reasonably find the facts as it did.9= Friends of Lincoln Lake v. Bd. of Envtl.

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Related

Maine Taxpayers Action Network v. Secretary of State
2002 ME 64 (Supreme Judicial Court of Maine, 2002)
Allen v. Quinn
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Knutson v. Department of Secretary of State
2008 ME 124 (Supreme Judicial Court of Maine, 2008)
Friends of Lincoln Lakes v. Board of Environmental Protection
2010 ME 18 (Supreme Judicial Court of Maine, 2010)
Anderson v. Maine Public Employees Retirement System
2009 ME 134 (Supreme Judicial Court of Maine, 2009)
Seider v. Board of Examiners of Psychologists
2000 ME 206 (Supreme Judicial Court of Maine, 2000)
Kroeger v. Department of Environmental Protection
2005 ME 50 (Supreme Judicial Court of Maine, 2005)
Palesky v. Secretary of State
1998 ME 103 (Supreme Judicial Court of Maine, 1998)
State v. Cropley
544 A.2d 302 (Supreme Judicial Court of Maine, 1988)
Passadumkeag Mountain Friends v. Board of Environmental Protection
2014 ME 116 (Supreme Judicial Court of Maine, 2014)
McGee v. Secretary of State
2006 ME 50 (Supreme Judicial Court of Maine, 2006)