Lalumiere v. Sea View Homeowners Association

CourtSuperior Court of Maine
DecidedDecember 20, 2018
DocketCUMre-18-142
StatusUnpublished

This text of Lalumiere v. Sea View Homeowners Association (Lalumiere v. Sea View Homeowners Association) 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
Lalumiere v. Sea View Homeowners Association, (Me. Super. Ct. 2018).

Opinion

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STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss . CIVIL ACTION DOCKE~ NO. RE-18-14¥

MARILYN LALUMIERE and MARIE KOERICK,

Plaintiffs ORDER ON DEFENDANT'S MOTION TO DISMISS V.

SEA VIEW HOMEOWNERS ASSOCIATION, :~~t~'tt r:, =-"-"- '-'' ··-~ ~--

Defendant

Before the court is defendant's motion to dismiss. For the following reasons, the motion is

denied as to counts I-VI and granted partially and denied partially as to counts VII and VIII.

Defendant's motion for a more definitive statement is denied.

Standard

When ruling on a motion to dismiss for failure to state a claim pursuant to M.R. Civ. P.

12(b)(6), the court views the "facts alleged in the complaint as if they were admitted." Nadeau v.

Frydrych, 2014 ME 154, ~ 5, 108 A.3d 1254 (per curiam) (quotation marks omitted). A complaint

need only set forth the "elements of a cause of action or allege[] facts that would entitle the plaintiff

to relief pursuant to some legal theory." Id. Facts are read in the light most favorable to the

plaintiff. Id.

Rule 8 requires "a short and plain statement of the claim showing that the pleader is entitled

to relief." M.R. Civ. P. 8(a). "Notice pleadings requirements are forgiving; the plaintiff need only

give fair notice of the cause of action by providing a short and plain statement of the claim showing

that the pleader is entitled to relief." Desiardins v. Reynolds , 2017 ME 99, ~ 17, 162 A.3d 228

(quotation marks omitted).

1 ( (

Counts I-IV: Prescriptive Easements

In order to prevail on a motion to dismiss, plaintiffs must allege in their prescriptive

easement claim continuous use for at least 20 years, a claim of right adverse to the owner, and the

use was with the knowledge and acquiescence of the owner or was "a use so open, notorious,

visible, and uninterrupted that knowledge and acquiescence will be presumed." Dowley v.

Morency, 1999 ME 137,, 23,737 A.2d 1061 (quoting Shadan v. Town of Skowhegan, 1997 ME

187,, 6,700 A.2d 245); see al so 14 M.R.S. § 812 (2016) ("No person ... shall acquire a right-of­

way or other easement through, in, upon or over the land of another by the adverse use and

enjoyment thereof, unless it is continued uninterruptedly for 20 years.").

Plaintiffs allege that they and their predecessors in interest have used the property and the

lower parking lot continuously for 20 years, that they have used the property adverse to the owner,

and that they did so with the knowledge and acquiescence of the owner of the property or with a

use such that knowledge and acquiescence will be presumed. (Pis.' Comp!.,, 4, 19-20, 22, 24­

25, 27), Plaintiffs allege sufficient facts to support their prescriptive easement claims.

Count V: Decl aratory Judgment

Pursuant to the Paper Streets Act:

From the date of recording of a subdivision plan in the registry of deeds, the public acquires rights of incipient dedication to public use of the ways laid out on the plan . If a proposed way laid out in the plan is not accepted by the municipality within 20 years from the date of recording of the plan, the public rights in that way terminate.

23 M.R.S. 3031(1) (2016). Plaintiffs allege that the defendant's most recent subdivision plan

depicting Ravine Road was submitted in 2005. (Pis.' Comp!. i 32.) Plaintiffs further allege that

the town of Falmouth has not acted in respect to Ravine Road. (Pis.' Comp1. , 33 .) Defendant

argues that Ravine Road is a private way due to its depiction on the Underwood Plan and the lack

2 of construction or use as a way. See Fournier v. Elliot, 2009 ME 25,, 15,966 A.2d 410 ("[T]he

term 'proposed, unaccepted way' is indicative of the status of a subdivision road as it pertains to

its potential adoption by a municipality, not as it pertains to its physical construction.").

Count VI: Quiet Title

Plaintiffs' claim for quiet title is brought pursuant to 23 M.R.S. § 3033 (2016) and 14

M.R.S. § 6651 (2016). (Pls.' Compl. !! 35-39.) A party claiming ownership of a vacated way

must post a notice claiming ownership with the registry of deeds where the way is located and give

notice to current owners of lots on the subdivision plan on which the vacated way is located . 23

M.R.S. § 3033(1). Once notice has been given, a claimant who disputes the first party's claim

must record a statement with the registry of deeds within one year of the original notice specifying

the claimed interest and commence an action in equity within 180 days of filing his statement. Id.

§ 3033(2). In the following quiet title proceeding, the court may find in favor of the claimant only

if "the claimant has acquired an interest in the way" pursuant to a quiet title theory, and "a

deprivation of the claimant's rights will unreasonably limit access from his or her land to a public

way, a public body of water, or common land or a common facility within the subdivision."

Glidden v. Belden, 684 A.2d 1306, 1315 (Me. 1996). In order to bring a claim under 14 M.R.S.

§ 6651, plaintiffs must allege "uninterrupted, i.e. continuous and exclusive, possession for the four

years preceding the commencement of the action." Levis v. Koni tzky, 2016 ME 167, , 24, 151

A.3d 20.

Plaintiffs allege their title is traced to the Underwood Plan and acquired a right to use the

ways in the subdivision. (Pis.' Compl." 12, 16.) Plaintiffs allege they acquired title to Glenn

Road, which surrounds Ravine Road. (Pis.' Compl. n 1-2, 4.) Plaintiffs allege that they have maintained continuous and exclusive use of the property for more than twenty years. (Pis.' Compl.

3 ! 22.) Additionally, plaintiffs allege that access to Ravine Way is necessary for them to access their properties from the public way. (Pis.' Compl. ! 39.)

With regard to counts V and VI, the parties rely on two plans and other documents for their

arguments. Defendant states that the court may consider the documents on this motion to dismiss.

See Moody v. State Liquor & Lottery Comm ' n, 2004 ME 20, ! 11, 843 A.2d 43. Although

defendant is correct, the court declines to consider the documents and decide these issues without

the procedural benefits that accompany a motion for summary judgment. See M.R. Civ. P. 56(e)

& (h).•

Count VII: Promissory Estoppel

The Law Court relies on the definition of promissory estoppel set out in the Restatement

(Second) of Contracts:

A promise which the promisor should reasonably expect to induce action or forbearance on the part of the promise or a third person and which does induce such action or forbearance is binding if injustice can be avoided only by enforcement of the promise. The remedy granted for breach may be limited as justice requires.

Harvey v. Dow, 2008 ME 192, ! 11, 962 A.2d 322. Plaintiffs allege that the subdivision developer,

the defendant's successor in interest, knew that plaintiffs used Ravine Road for parking. (Pis.'

Compl. ! 7, 43 .) Plaintiffs allege the developer told plaintiffs that their use of Ravine Road would

not be interrupted by the subdivision development plan. (Pis.' Compl. !! 8-9, 41.) Finally,

plaintiffs allege that as a result of this promise the plaintiffs refrained from opposing the

development plan. (Pis.' Compl. ! 41.)

Defendant argues, among other things, that plaintiff Koerick could not have relied on the

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Related

Moody v. State Liquor & Lottery Commission
2004 ME 20 (Supreme Judicial Court of Maine, 2004)
Charlton v. Town of Oxford
2001 ME 104 (Supreme Judicial Court of Maine, 2001)
Dowley v. Morency
1999 ME 137 (Supreme Judicial Court of Maine, 1999)
Shadan v. Town of Skowhegan
1997 ME 187 (Supreme Judicial Court of Maine, 1997)
Harvey v. Dow
2008 ME 192 (Supreme Judicial Court of Maine, 2008)
Glidden v. Belden
684 A.2d 1306 (Supreme Judicial Court of Maine, 1996)
Robert M.A. Nadeau v. Lynnann Frydrych
2014 ME 154 (Supreme Judicial Court of Maine, 2014)
James N. Levis v. Gustav Konitzky
2016 ME 167 (Supreme Judicial Court of Maine, 2016)
Dana Desjardins v. Michael Reynolds
2017 ME 99 (Supreme Judicial Court of Maine, 2017)
Fournier v. Elliott
2009 ME 25 (Supreme Judicial Court of Maine, 2009)
Cox v. Maine Maritime Academy
122 F.R.D. 115 (D. Maine, 1988)

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