Fiandaca v. City of Bangor

CourtSuperior Court of Maine
DecidedJune 5, 2002
DocketPENcv-01-136
StatusUnpublished

This text of Fiandaca v. City of Bangor (Fiandaca 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
Fiandaca v. City of Bangor, (Me. Super. Ct. 2002).

Opinion

STATE OF MAINE SUPERIOR COURT

PENOBSCOT, SS. CIVIL ACTION Docket No. CV-01-136 . ‘oe Ph Ys Bee NOL

Cebrina Fiandaca, by and through Lori Peterson, Plaintiff

FILED & ENTERED v. SUPERIOR COURTotrder on Defendant’s Motion

JUN 05 2602 for Summary Judgment

_GARBRECHT’ City of Bangor et al. | PENOBSCOT COUNTY a0 LIBRARY

Defendants

PJUN 14 2002

Pending before the court is the defendants’ motion for summary judgment on all claims filed by the plaintiff. The motion at bar rests on the defendants’ contention that they are immune from liability under the provisions of the Maine Tort Claims Act, 14 MLR.S.A. § 8101 et seg. (“CMTCA”). The court has considered the parties’ written arguments and other materials filed in association with the motion pursuant to M.R.Civ.P. 56.

The record on summary judgment establishes that on October 31, 2000, Cebrina Fiandaca was a student at the Vine Street Elementary School in Bangor, which is a public school. School had recessed for the day, and Cebrina and other students were outside of the school building waiting for the school bus. Two teachers from the Vine Street school supervised the children. Those teachers had the responsibility to supervise the students while they waited for the bus to pick them up and to escort them onto the bus. The record

at bar does not include any competent evidence of the existence of a policy governing

' The plaintiff urges that, as an alternative to granting the motion, the court defer consideration of the summary judgment motion to allow the parties to pursue additional discovery. This position, however, is not predicated on a proper procedural basis, see M.R.Civ.P. 56(f), or on an adequate substantive one, see, e.g., Selby v. Cumberland County, 2002 ME 80, {fj 14-15, --- A.2d ---, ---. those activities in which the supervising teachers could allow the children to engage.” On October 31, the supervising teachers decided to allow the students, including Cebrina, to use equipment in the playground. The plaintiff alleges that Cebrina (her daughter) fell from the playground equipment and sustained personal injury.

The plaintiff brought this action against the City of Bangor and, by an amended complaint, against the Bangor School Department, alleging that the defendants were negligent, first, in the operation, maintenance and control of the playground equipment, second, in the training of the supervising teachers; and third, in the supervision of the students provided by the teachers themseives. In support of their motion for summary judgment, the defendants contend that the equipment was not appurtenant to a public building and therefore that a negligence claim relating to that equipment does not fall with the immunity exception found in section 8104-A (2). The defendants next contend that the claims of negligent training and negligence supervision are barred by the MTCA because they involve discretionary functions that do not expose a governmental entity to civil liability.’ The plaintiff argues that “as a matter of law,” the defendant is not protected from liability from sovereign immunity. She does not argue that there exist genuine issues of material fact that leave the immunity claims open for factual resolution. Therefore, the court does not address the procedural issue noted in Campbell v. Washington County Technical College, 219 F.3d 3, 8 (1* Cir. 2000) — an issue not raised or addressed by the parties at bar — of whether a judge or a jury is the proper decision- maker of an immunity claim based on an undisputed record. Therefore, based on the manner in which the parties have framed their arguments, the court treats the pending

summary judgment motion, which has been presented on the basis of undisputed facts, as

2 Cebrina’s mother, who is the nominal plaintiff, believes that there is a policy that prohibits the supervising school personnel from allowing kindergarten children to use playground equipment that could be used by older children. See DSMF 7. Her belief, without more, is insufficient to create a proper evidentiary argument that such a policy in fact exists.

>In their motion, the defendants make the additional argument that they are not exposed to liability because of the liability insurance coverage that may be available here. The plaintiff’s response makes clear that she does not rely on that coverage as a basis for her claim that the defendants are not immunized from suit. Thus, the court does not address that issue here. one where the parties invite the court to make the ultimate determination of whether the defendants are entitled to immunity against the claims filed by the plaintiff.

Summary judgment is a proper vehicle for consideration of sovereign immunity. Dubail v. Department of Transportation, 1998 ME 126, J 7, 711 A.2d 1301, 1303. Exceptions to immunity are to be construed strictly. Id., | 6, 711 A.2d at 1303. “(I]mmunity is the rule and exceptions to immunity are to be strictly construed. . . . [The court shall employ] an exception-to-immunity approach rather than an exception-to- liability approach.” New Orleans Tanker Corp. v. Department of Transportation, 1999 ME 67, 15, 728 A.2d 673, 675 (citations and internal punctuation omitted).

Each defendant is a “governmental entity” for purposes of the MTCA and is therefore entitled to any immunity available thereunder. See 14 M.R.S.A. §§ 8102(2),

(3).

A. Public building and appurtenances

“A governmental entity is liable for its negligent acts or omissions in the construction, operation or maintenance of any public building or the appurtenances to any public building.” 14 M.R.S.A. 8104-A(2). The plaintiff alleges that the defendants were negligent in maintaining and operating of the playground equipment because that equipment was not equipped with a sufficiently cushioned surface to absorb the fall of a child. DSMF {7. Any such theory of negligence could be maintained against the defendants only if the playground equipment were appurtenant to the school building, which is a public building, see Lynch v. Town of Kittery, 677 A.2d 524, 525 (Me. 1996) (public school is a public building). The playground equipment that Cebrina allegedly used is located “just to the right of the front door of the [school] building on the Larkin Street side of the building. The playground equipment is also located directly in front of the doors leading to the gymnasium/cafeteria section of the school building.” DSMF { 8.

The research efforts of the parties and of the court have not revealed any Maine authority that discusses the concept of an appurtenance either in a general way, or ina more specific way that lends insight into the circumstances of this case. However, . Kitchen vy. City of Calais, 666 A.2d 77 (Me. 1995) demonstrates the very limited class of assets that could be treated as appurtenances for purposes of the MTCA. There, the plaintiff sustained injury when she fell over a curb in a public parking lot that serviced © the City’s police station. The Court held that the parking lot could not be an appurtenance to the public building (the police station) because of the effect that a contrary conclusion would have on section 8104-A(2). Id. at 78-79. The specific analysis that led the Kitchen Court to its finding in that case is not applicable here, because Cebrina did not sustain any injuries in a parking lot. Nonetheless, Kitchen is instructive because it demonstrates the highly restricted nature of an appurtenance, as that term in used in the MTCA.

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Related

New Orleans Tanker Corp. v. Department of Transportation
1999 ME 67 (Supreme Judicial Court of Maine, 1999)
Selby v. Cumberland County
2002 ME 80 (Supreme Judicial Court of Maine, 2002)
Erskine v. Commissioner of Corrections
682 A.2d 681 (Supreme Judicial Court of Maine, 1996)
Lynch v. Town of Kittery
677 A.2d 524 (Supreme Judicial Court of Maine, 1996)
Dubail v. Department of Transportation
1998 ME 126 (Supreme Judicial Court of Maine, 1998)
Stretton v. City of Lewiston
588 A.2d 739 (Supreme Judicial Court of Maine, 1991)
Kitchen v. City of Calais
666 A.2d 77 (Supreme Judicial Court of Maine, 1995)

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Bluebook (online)
Fiandaca v. City of Bangor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fiandaca-v-city-of-bangor-mesuperct-2002.