Friends of Congress Square Park v. City of Portland

CourtSuperior Court of Maine
DecidedAugust 8, 2014
DocketCUMap-13-055
StatusUnpublished

This text of Friends of Congress Square Park v. City of Portland (Friends of Congress Square Park v. City of Portland) 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
Friends of Congress Square Park v. City of Portland, (Me. Super. Ct. 2014).

Opinion

~RED AUG 2 gztdi STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss CIVIL ACTION DOCKET NO. AP-13-055

FRIENDS OF CONGRESS vA'AJ-(/LU'Y)- rlb-JZ-14 SQUARE PARK, et al.

Plaintiffs ORDER ON MOTION v. FORAWARDOF ATTORNEYS' FEES CITY OF PORTLAND,

Defendant ACG 18 20'14 .. \ ~--.~ . .~ ' ' <~:. ""'~t Before the court is plaintiffs' motion for an award of attorneys' fees and' · ... '

costs. On May 6, 2014, the Law Court affirmed this court's decision finding in

plaintiffs' favor on counts I and II of their complaint regarding the City's refusal

to issue citizens' initiative petition forms. Friends of Cong. Square Park v. City of

Portland, 2014 ME 63,

prevailed on appeal, the City is liable on count III of plaintiffs' complaint under

42 U.S.C. § 1983. Id.

reasonable attorneys' fees to the prevailing party on a section 1983 claim. 42

U.S.C. § 1988 (2012); Doe I v. Williams, 2013 ME 24,

special circumstances would render such an award unjust, the general rule is that

the prevailing party is entitled to an award of attorneys' fees." IMS Health Corp.

v. Schneider, 901 F. Supp. 2d 172, 187 (D. Me. 2012) (quotation marks omitted).

The City argues that special circumstances make an award of attorneys'

fees unjust in this case. "The special circumstances warranting the complete

denial of attorneys' fees are narrowly circumscribed." Cushing v. McKee, 853 F.

Supp. 2d 163, 171 (D. Me. 2012) (quotation marks omitted). Special circumstances that permit the denial of a fee award "are few and far between." De Jesus Nazario

v. Morris Rodriguez, 554 F.3d 196, 200 (1st Cir. 2009).

The City relies on Schock v. United States, which involved a claim for

attorneys' fees under the Equal Access to Justice Act ("EAJA"), 42 U.S.C. § 2412.

Schock v. United States, 254 F.3d 1 (1st Cir. 2001). The City argues that its position

in this case was justified even though the City ultimately lost the case because the

law in Maine was unclear on the distinction between legislative and

administrative matters. Unlike § 1988, the EAJA requires a court to award fees

"unless the court finds that the position of the United States was substantially

justified or that special circumstances make an award unjust." 42 U.S.C. §

2412(d)(l)(A) (emphasis added). The "substantially justified" language is absent

from 42 U.S.C. § 1988. Schock is therefore not relevant to this case.

Federal courts have held that "mere uncertainty in the law is not a 'special

circumstance' justifying rejection of a statutory award of attorney fees in a civil

rights action." Northcross v. Bd. of Ed. of Memphis City Schs., 611 F.2d 624, 635 (6th

Cir. 1979); see also J & J Anderson, Inc. v. Town of Erie, 767 F.2d 1469, 1474 (lOth Cir.

1985) (stating that "good faith" and "uncertainty in the law" do not amount to

special circumstances under§ 1988). As the Northcross court explained, "[a] major

purpose of the Fees Awards Act was to encourage the bringing of suits in new

and undeveloped areas of civil rights law, and it would be anomalous indeed ...

to deny fees for the very reason the statute was passed." Northcross, 611 F.2d at

635. The City has failed to articulate a valid special circumstance to justify

denying plaintiffs' fee award.

Furthermore, although the City contends that it acted in good faith to

protect its rights in. this case, the Court notes that the City withheld the citizens' initiative petition forms without any legal justification.' See Friends of Cong. Square

Park, 2014 ME 63, 'IT 4 n.3, 91 A.3d 601 ("The City Clerk does not have express

authority to reject citizens' initiative proposals submitted in compliance with the

petition procedure in the City Code on the grounds that they are not

legislative.") The City forced plaintiffs to file suit and litigate on an expedited

schedule just to obtain the requested petition forms. As the City concedes,

municipalities must proceed with caution when constitutional rights are

involved and should err on the side of ensuring the free exercise of political

speech.

The City does not contest the reasonableness of plaintiffs' fee request,

which is supported by affidavits from counsel. Accordingly, plaintiffs' motion is

granted in full.

The entry is:

Plaintiffs' motion for award of attorneys' fees is GRANTED.

Plaintiffs are awarded their attorneys' fees and costs in the amount of $50,834.50, plus post-judgment interest at 6.16% calculated from the October 31, 2013 judgment.

Dated: August 18, 2014 ~Wheeler Justice, Superior Court

Plaintiffs-Sarah McDaniel Esq Robert Levin Esq Defendant-Danielle West-Chuhta Esq Jennifer Thompson Esq

• Plaintiffs waived this argument, likely out of a desire to avoid further litigation. STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss CIVIL ACTION DOCKET NO. A~-)3-0?5 . .JAW- cu..M- ;o;ai ;z_o;3 FRIENDS OF CONGRESS SQUARE PARK, FRANK R. TUREK, DAVID R. LaCASSE, HERBERT C. ADAMS, and PATRICIAM. O'DONNELL Plaintiffs ORDER ON SOB APPEAL v. AND MOTION FOR SUMMARY JUDG~ENfA~''~ ~ . CITY OF PORTLAND r_;r~~rnh~;:!:-,;"' ~ f"·

Defendant ocr 31 2013 Plaintiffs challenge the City of Portland's refusal to provide them the required~ ~:~ i

petition forms to gather signatures for a ballot initiative under the Portland City Code.

Factual and Procedural Background

Friends of Congress Square Park ("Friends") is a Maine nonprofit corporation

incorporated on July 15, 2013. (Pls.' S.M.F. ~ 2.) The individual plaintiffs are all Portland

citizens, registered voters, and board directors or officers of Friends. (Pls.' S.M.F. ~~ 1,

3.) Friends was formed in response to a proposal in 2013 to sell a portion of Congress

Square Park to a private developer. (Compl. ~ 10.) The organization ultimately adopted a

strategy of petitioning for a ballot initiative that would strengthen the current Land Bank

ordinance to protect Congress Square and other city parks. (Compl. ~ 11.)

The Land Bank Commission was established by the City Council in 1999. The

Commission manages the Land Bank properties and recommends properties for potential

Land Bank dedication. Under current law, the City Council alone has the authority to

approve any new acquisitions or dispositions of Land Bank properties. On September 6, 2013, plaintiffs submitted a citizen petition ("Park Initiative") to

the Clerk of the City of Portland. (Pls.' S.M.F. ~ 7.) The Park Initiative would accomplish

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Related

Schock v. United States
254 F.3d 1 (First Circuit, 2001)
De Jesus Nazario v. Morris Rodriguez
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Aydelott v. City of Portland
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Citizens for Jobs & the Economy v. County of Orange
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Friends of Congress Square Park v. City of Portland
2014 ME 63 (Supreme Judicial Court of Maine, 2014)
John Doe I v. Robert Williams
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Burkett v. Youngs
199 A. 619 (Supreme Judicial Court of Maine, 1938)
Casco Northern Bank, N.A. v. Board of Trustees of Van Buren Hospital District
601 A.2d 1085 (Supreme Judicial Court of Maine, 1992)
Cushing v. McKee
853 F. Supp. 2d 163 (D. Maine, 2012)
IMS Health Corp. v. Schneider
901 F. Supp. 2d 172 (D. Maine, 2012)
Northcross v. Board of Education
611 F.2d 624 (Sixth Circuit, 1979)
J & J Anderson, Inc. v. Town of Erie
767 F.2d 1469 (Tenth Circuit, 1985)

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