Higgins v. Penobscot County Sheriff's Department

446 F.3d 11, 2006 U.S. App. LEXIS 9318, 2006 WL 964859
CourtCourt of Appeals for the First Circuit
DecidedApril 14, 2006
Docket05-2375
StatusPublished
Cited by21 cases

This text of 446 F.3d 11 (Higgins v. Penobscot County Sheriff's Department) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Higgins v. Penobscot County Sheriff's Department, 446 F.3d 11, 2006 U.S. App. LEXIS 9318, 2006 WL 964859 (1st Cir. 2006).

Opinions

PER CURIAM.

This case arises from an incident in which defendant Joshua Tibbetts, a deputy sheriff with the Penobscot County Sheriffs Department, issued plaintiff Barry Higgins a no-trespass warning and ordered him to leave the T & N Trailer Park in Carmel, Maine. The district court granted the defendants (Tibbetts, Tibbetts’ supervisor Sheriff Glenn Ross, and the Department itself) summary judgment on Higgins’ claims that' defendants deprived him of his Fourth and Fourteenth Amendment rights and certain other rights secured him under Maine common law. The court also granted defendants judgment on the pleadings on Higgins’ claim under Maine’s unlawful eviction statute, 14 M.R.S.A. § 6014. Hig[12]*12gins brings this appeal to challenge these rulings.

The incident giving rise to this case occurred on May 16, 2002. The undisputed facts and the disputed facts taken in a light favorable to Higgins, see, e.g., APG, Inc. v. MCI Telecommunications Corp., 436 F.3d 294, 297 (1st Cir.2006), are that Higgins awoke that morning in an apartment over a garage built on a lot within the trailer park. While he was drinking coffee in his robe, Higgins heard someone closing a door below, in the garage. Higgins opened the door to the apartment and saw his sister Irene standing outside near the base of a ladder that he had used to access the apartment. (Apparently, there previously was a deck with steps leading up to the apartment, but the deck and steps had been removed). Higgins asked Irene what she was doing in his garage. Irene retorted that Higgins had no right to be there and that she was going to call the sheriff. But before she could do so, Higgins called the sheriffs department and asked for assistance.

There had been a long-running dispute between Higgins and his family over Higgins’ rights vis-á-vis the building and certain of its contents. Those members of Higgins’ family who have submitted evidence in this case deny that Higgins had any right to be in the building on the day of the incident. Higgins responds that, at the very least, he had a tenancy interest in the building. He alleges that he and his father, Leo, formed a partnership and purchased the trailer park in 1972, agreeing at the time that all members of the Higgins family would have a lifetime right to reside there. Higgins says that he paid for and built the apartment and garage, completing construction in 1981, and that he “resided” in the building from 1981 to the day of the incident. Higgins admits to having spent significant periods of time out of state beginning in the late 1990s, and to having signed his partnership interest over to his father during his divorce proceedings in 1989, with the as-yet unrealized expectation that his father would deed the interest back to him after the proceedings concluded. But he maintains that his “long-term possession and occupancy of the building, at a minimum, give rise to a tenancy interest, even in the absence of agreement with his father as to its terms.”

Deputy Tibbetts was dispatched to the trailer park in response to Higgins’ call. Upon arriving, Tibbetts encountered what Higgins described in his deposition as a “screaming contest” involving, at the very least, himself and his sisters Irene and Cynthia, as well as Cynthia’s husband David Prescott. Higgins informed Tib-betts that he and his father were engaged in an ongoing disagreement over ownership of the property and his right to reside there. Leo showed up a short time later with a copy of the deed, which he showed to Tibbetts, telling him that he previously had notified Higgins to stay off the property. Leo asked Tibbetts to bar Higgins from the property. Higgins informed Tib-betts that the police had more than once been summoned to mediate the issue but always had declined to involve themselves, telling Higgins and Leo that it was a “civil dispute and that [they] would not get involved.”

In due course, Tibbetts issued Higgins the no-trespass order that is the subject of this lawsuit and gave him several minutes to collect some personal belongings from the apartment. Several facts, in addition to Leo’s apparent ownership of the building, led Tibbetts to believe that Higgins was a trespasser and was not lawfully entitled to occupy the apartment: the truck Higgins had parked outside the building had Connecticut license plates; there were no stairs, only a ladder, to [13]*13access the building’s apartment; and Tib-betts had driven past the building on “many, many” prior occasions and it always had appeared vacant — i.e., there never were any lights on, there never were any vehicles parked outside, and there was “lots of junk in the dooryard that was always in the same place.” (The word “dooryard,” as used colloquially in northern New England and eastern Canada, typically refers to the area outside the most commonly used entrance to a residence, and often includes the driveway. See Walt Whitman, When Lilacs Last in the Dooryard Bloom’d (1865-66)). Tibbetts told Higgins that he would be arrested if he did not leave or if he returned to the property. Higgins says that he asked Tibbetts to look in the apartment and to take note of the personal property that he would be leaving behind, but Tibbetts refused. Higgins says that, after he complied with Tibbetts’ order and departed, a great deal of his personal property disappeared from the building.

Eventually, Higgins filed this action. He asserted three federal civil rights claims: that his “eviction” constituted (1) a “meaningful interference with ... [his] possessory interests” in his residence, and thus an unlawful seizure in violation of the Fourth Amendment, see Soldal v. Cook County, 506 U.S. 56, 61, 113 S.Ct. 538, 121 L.Ed.2d 450 (1992) (citation and internal quotation marks omitted); (2) an abridgment of his right to procedural due process protections before the seizure, see Fuentes v. Shevin, 407 U.S. 67, 87, 92 S.Ct. 1983, 32 L.Ed.2d 556 (1972); and (3) a violation of his right to have had Tibbetts properly trained and supervised by the other defendants, see, e.g., City of Oklahoma City v. Tuttle, 471 U.S. 808, 813-24, 105 S.Ct. 2427, 85 L.Ed.2d 791 (1985). He also asserted state law claims for conversion of his personal property and the infliction of emotional distress. Finally, as noted at the outset, Higgins pressed a claim under Maine’s unlawful eviction statute, 14 M.R.S.A. § 6014.

Following discovery, the defendants moved for summary judgment on all claims except the claim for wrongful eviction, on which they moved for judgment on the pleadings. The matter was referred to a magistrate judge, who issued a thorough and carefully reasoned report recommending that the defendants’ motions be granted. The magistrate judge expressed considerable doubt that a viable constitutional claim was stated under either the Fourth or Fourteenth Amendments, but concluded that, in any event, the defendants should be entitled to qualified immunity from the claims because they had not violated Higgins’ “clearly established” rights. See Harlow v. Fitzgerald, 457 U.S. 800, 818, 102 S.Ct. 2727, 73 L.Ed.2d 396 (1982); Anderson v. Creighton, 483 U.S. 635, 640, 107 S.Ct.

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Higgins v. Penobscot County Sheriff's Department
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Bluebook (online)
446 F.3d 11, 2006 U.S. App. LEXIS 9318, 2006 WL 964859, Counsel Stack Legal Research, https://law.counselstack.com/opinion/higgins-v-penobscot-county-sheriffs-department-ca1-2006.