Knowlton v. Rowe

CourtSuperior Court of Maine
DecidedJuly 17, 2007
DocketPENcv-06-206
StatusUnpublished

This text of Knowlton v. Rowe (Knowlton v. Rowe) 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
Knowlton v. Rowe, (Me. Super. Ct. 2007).

Opinion

STATE OF MAINE SUPERIOR COURT PENOBSCOT, SSe CIVIL ACTION DOCKET ,'''' NO. CV-06-206 -....~ 1;---,_,,",' I ,\.( r ; f, I.!i,l . _ --....,,­ j - 'Ii! c ,',

ALAN D. KNOWLTON, )

Plaintiff, ) ) I-F'I L~E::;'·:~'·:':\'.' ;'.:."':;~~:~-lfl· (,ll''''C.) ....;. 't.J i~ 1 (,:., r: . . !lRT '

) v. ) \ Jt i! t "/ ZL~ '1 \ PEN08~COT COUNTY : ) ) ORDER \ G. STEVEN ROWE, et al., ) ) l_.. _-----·--·--·..------' Defendant. ) 'i>~~C'/ r"~ , \ (. \" v' 0 I>-~"'( .' \\~~. This matter is before the court on a Rule 26(g) .;

1 't~~\c discovery dispute regarding whether the plaintiff may ~~~ \) depose the defendants' attorney and obtain other documents

and information regarding certain insurance complaint

negotiations.

BACKGROUND

Plaintiff Alan Knowlton ("Knowlton") is a former

employee of Bankers Life and Casualty Company ("Bankers

Life"). He was terminated pursuant to one of the terms of

a consent agreement entered into between Bankers Life and

the defendants in this matter, the Maine Attorney General's

office and the Superintendent of the Bureau of Insurance

(collectively referred to in this order as "the State").

The consent agreement reportedly represented the

culmination of negotiations pertaining to consumer

complaints received by the State against Bankers Life between 2002 and 2005. The Bankers Life consent agreement

with the State was executed on April 11, 2005.

Knowlton had reached an earlier consent agreement with

the State when he was accused of misrepresenting the

financial strength rating of Bankers Life in a recruiting

effort. This consent agreement provided, among other

things, that the State would forgo any other disciplinary

action against Knowlton with respect to his misconduct.

The Knowlton consent agreement with the State was executed

on March 28, 2005. In fact, following the execution of the

State/Bankers Life consent agreement, Knowlton was fired

consistent with the terms of that agreement which directed

that he be fired.

In his original complaint against the State, Knowlton

brought suit under separate contract and tort claims for

violation of his personal consent agreement with the State.

At that time, he requested to depose the State's attorney,

Assistant Attorney General Andrew Black (UAttorney Black"),

regarding the negotiations that led into the consent

agreement between the State and Bankers Life. In addition,

he requested that Attorney Black provide any documents

relating to such negotiations. The State objected on

grounds of statutory confidentiality pursuant to 24

M.R.S.A. § 206(2). Justice Mead sustained the objection in

2 a March 7, 2007 order, stating: nThe court is satisfied

that the negotiation process is subject to statutory

confidentiality. The court is further satisfied that the

current configuration of the matter does not justify

judicial abrogation of the confidentiality established by

the statute." However, Justice Mead did state that the

issue could be raised without prejudice should Knowlton's

tort claims survive a motion for summary judgment on the

procedural issues.

Following this order, however, Knowlton agreed to

dismiss his tort claim, acknowledging that it was barred by

the Maine Tort Claims Act. Subsequently, the court granted

Knowlton's request to amend his complaint in order to

incorporate several claims under 42 U.S.C. § 1983. In

order to obtain evidence in support of his 1983 claims,

Knowlton renewed his request for Attorney Black's

deposition, which brings us to the discovery dispute now

before the court.

DISCUSSION

The defendants renew their argument that the

negotiation process is subject to confidentiality

provisions of Maine statutory law. Pursuant to the Maine

Insurance Code, all Bureau records are subject to public

inspection except for nrecords, correspondence and reports

3 of investigation in connection with actual or claimed

violations of this Title or prosecution or disciplinary

action for those violations," which are confidential. 24-A

M.R.S.A. § 216(2). Nonetheless, "[a]ll records and

documents of the bureau are subject to subpoena by a court

of competent jurisdiction." Id. § 216(3). That suggests

to the court that there are limits on the claim for

confidentiality by the State.

The State first directs the court to Justice Mead's

March 2007 order and argues that the court cannot now allow

the deposition pursuant to the doctrine of the law of the

case. This doctrine applies to "proceedings involving the

same case." Monopoly, Inc. v. Aldrich, 683 A.2d 506, 510

(Me. 1996) (quoting Grant v. City of Saco, 436 A.2d 403,

405 (Me. 1981)). This is not the same "configuration" that

was before Justice Mead and which was the subject of his

order. As such, the court has authority to examine the

discovery motion with regard to the current case posture.

Second, the State argues that there are "several

flaws" in each of Knowlton's 1983 claims and, in this

sense, "Knowlton's constitutional claims have no more

potential viability than did his barred tort claim."

(State's Mem. of Law at 3-4). Although the defendants

question the validity of the 1983 claims, this dispute is

4 before the court solely on a discovery dispute and not as a

motion to dismiss.

Having addressed these initial arguments, this court

finds that the plaintiff should have the opportunity to

develop his case. Although the 1983 claims are separate

and distinct from the now dismissed tort claims, the State

previously recognized with respect to the tort claims that

uMr. Knowlton is at least entitled to the opportunity to

attempt to develop his case." (State's 2/23/2007 Mem. of

Law at 6). Likewise, Knowlton is entitled the opportunity

to develop his 1983 claims. Furthermore, section 216(2) is

concerned with public exposure to records and other

information concerning investigations and negotiations

pertaining to insurance violations. As the State points

out, there is a risk that public exposure to the

information requested by Knowlton would chill ucandid

exchange of information in Bureau investigations."

(State's Mem. of Law at 5). In order to prevent such a

chilling effect, the court can and does order, pursuant to

its subpoena power under section 216(3), that Knowlton will

be able to take the deposition of Attorney Black, however,

in the interest of preventing inappropriate public exposure

of the Bureau's 'records,' all records and transcripts from

the deposition, including deposition exhibits, will remain

5 confidential and will be kept in the custody of each

counsel who appear in this litigation for use exclusively

in this litigation. Copies of the deposition transcript

will not be provided to any third parties (including expert

consultants for any party) without an order of the Court

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Knowlton v. Rowe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/knowlton-v-rowe-mesuperct-2007.