Hodsdon v. Town of Hermon

CourtSuperior Court of Maine
DecidedMarch 2, 2001
DocketPENap-99-28
StatusUnpublished

This text of Hodsdon v. Town of Hermon (Hodsdon v. Town of Hermon) 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
Hodsdon v. Town of Hermon, (Me. Super. Ct. 2001).

Opinion

STATE OF MAINE SUPERIOR COURT PENOBSCOT, SS. Docket No. AP-99-28

Tl he Pew 72 Re Qo!

Marilyn Hodsdon et al.,

Appellants v. ORDER ON APPEAL Town of Hermon, - Appellees FILED AND ENTERED SUPFRINR COUAT and MAR O2 2001 . Walter J. Munn et al., Parties in Interest | PENOBSCOT COUNTY

Marilyn Hodsdon and twenty-six other individuals (collectively, "Hodsdon") appeal directly from a decision of the Town of Hermon Planning Board ("the Board”), approving an application of the parties in interest, Walter Munn and Virginia Munn (collectively, "Munn"), for the construction of a campground on property owned by the Munns. On this — appeal, Hodsdon contends that the Board did not have authority to approve Munn’s application because of changes in the Town's ordinance relating to permitted uses. Hodsdon also argues that the Board's decision was not supported by sufficient evidence.

Subsequent to the submissions of the parties’ briefs but prior to oral

argument on this appeal, the Law Court issued its decision in Hodsdon v.

Town. of Hermon, 2000 ME 181, 760 A.2d 221.! There, on the basis of the Town's ordinances that also control the proceeding at bar, the Court concluded that with three specific exceptions, the Superior Court does not have jurisdiction over an appeal taken directly from the Town's Planning Board. Id. J] 4-6, 760 A.2d at 222-23. At oral argument, the parties agreed that the Court's holding in Hodsdon is applicable to this case. Because the briefing schedule in this case did not allow the parties an Opportunity to address the impact of the Law Court's decision in Hodsdon on this case, the court gave the parties leave to file additional argument on that issue if they wished to do so. None of the parties filed supplemental argument.

At oral argument, Hodsdon acknowledged that the Law Court's opinion in Hodsdon deprives the Superior Court of jurisdiction to consider her argument that the Board's decision was without sufficient factual support. Hodsdon contends, however, that her alternative argument is still viable. In that alternative challenge, she contends that the Board erred in considering Munn’s application. In 1998, Munn first filed his application for construction of the campground, which was a permitted use under the ordinance in effect at that time. The Board consisdered that application at a meeting held in October 1998. Effective November 21, 1998, the Town amended its zoning ordinance to remove campgrounds as a permitted use in the district where Munn hoped to establish the campground. The Board

had not issued a decision on Munn's application prior to the effective date

1The Law Court case involved the same parties who participate in the case at bar. That case, however, concerned Munn's application to build a restaurant, which would be on a parcel adjacent to the proposed campground at issue here.

2 of the zoning ordinance amendment. In February 1999, Munn filed a site plan review for the campground with the Board, which considered and ultimately approved the application. Hodsdon argues that Munn’s application was not pending as of November 21, 1998, that the amended ordinance thus controlled Munn’s application filed in February 1999 and that the Board was therefore without authority to approve the application on the basis of the ordinance that was effective prior to November 21, 1999,

At oral argument, Hodsdon urged that this direct challenge to the Board's decision is entirely a question of law and thus is cognizable under Hodsdon. 2000 ME 181, ¥ 6, 760 A.2d at 223 (a petitioner is not required to exhaust administrative remedies “where ‘(1) because of direct

involvement of the reviewing body in the initial decision, administrative

appeal would be futile, (2) only questions of law are involved, or (3) the

ur

reviewing body has no power to grant the requested relief. . (emphasis added; citation omitted)). The second exception noted by the Law Court,

which is the one pertinent to this case, can be traced back to Churchill v.

S.A.D. 49 Teacher's Association, 380 A.2d 186 (Me. 1977).2. There, one of the issues presented to the Court was whether a provision in a labor

contract violated a statute that governed the scope of binding arbitration. The Court held that "[t]he issue of the legality of the . . . agreement in the

instant case is one solely of law, wherein the special expertise of the

2This lineage leading back to Churchill is based not only on the substantive principle at issue, but also based on the specific authority cited by the Hodsdon Court:

Hodsdon expressly relies on Lakes Environmental Association v. Town of Naples. 486

A.2d 91, 96 (Me. 1984), which relies on’ Northeast Occupational Exchange, Inc. Bureau of Rehabilitation, 473 A.2d 406, 410-11 (Me. 1984), which cites Churchill itself,

3 administrative agency would be of no significant benefit." Id. at 190. Consequently, the appellate courts had jurisdiction over the issue even though the administrative body had not passed on it. Id.

The legal basis for Hodsdon's challenge is found in 1 M.R.S.A. § 302. Under that law, ". . .proceedings pending at the time of the passage,

amendment or repeal of an Act are not affected thereby." The statute goes on to provide:

an application for a license or permit required by law at the time of its filing shall be considered to be a pending proceeding when the reviewing authority has conducted. at least one substantive review of the application and not before. For purposes of this section, a substantive review of an application for a license or permit required by law at the time of application shall consist of a review of that application to determine whether it complies with the review criteria and other applicable requirements of law.

Id. Hodsdon argues that Munn's 1998 application had not given rise to a proceeding that was "pending" as of November 21, 1998, when the Town's zoning ordinance was amended in a way that, if applicable, would have foreclosed the proposed development. Under Hodsdon and Coolidge, this court could consider that claim only if the determination of a "pending

proceeding” is a pure legal issue.

In McCarthy v. City of South Portland, 571 A.2d 833 (Me. 1990), the

Law Court reviewed the trial court's determination that a development application was not pending on the date that a municipal ordinance was amended in a way that affected the merits of the application. The Court concluded that the trial court's determination “is supported by the record and is not clearly erroneous." Id. at 835. The "clearly erroneous" standard

is one that is applied to factual findings. See, e.g., Tarbuck v. Jaekel, 2000

ME 105, { 18, 752 A.2d 176, 181. Issues of law, on the other hand, are

subjected to de novo appellate review. See, e.g. Bangs v. Town of Wells, 2000 ME 186, J 9, 760 A.2d 632, 635. Because the McCarthy Court

reviewed the issue of pendency for clear error, it treated the issue as one

of fact rather than of law.?

The circumstances of this case support a similar conclusion. At the Board's hearing held on February 18, 1999, Hodsdon argued the November 1998 amendment to the Town's zoning ordinance deprived the Board of any authority to grant Munn’s application. (R. 11, T. 13-18.) Despite this challenge, the Board ultimately rejected it (R. 11, T. 24) and approved the application (R. 17).

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Related

Hodsdon v. Town of Hermon
2000 ME 181 (Supreme Judicial Court of Maine, 2000)
Bangs v. Town of Wells
2000 ME 186 (Supreme Judicial Court of Maine, 2000)
Churchill v. S. A. D. 49 Teachers Ass'n
380 A.2d 186 (Supreme Judicial Court of Maine, 1977)
LaFosse v. Champagne
2000 ME 81 (Supreme Judicial Court of Maine, 2000)
Tarbuck v. Jaeckel
2000 ME 105 (Supreme Judicial Court of Maine, 2000)
Lakes Environmental Ass'n v. Town of Naples
486 A.2d 91 (Supreme Judicial Court of Maine, 1984)
Larrivee v. Timmons
549 A.2d 744 (Supreme Judicial Court of Maine, 1988)
Northeast Occupational Exchange, Inc. v. Bureau of Rehabilitation
473 A.2d 406 (Supreme Judicial Court of Maine, 1984)
McCarthy v. City of South Portland
571 A.2d 833 (Supreme Judicial Court of Maine, 1990)

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