Legrand v. Nadeau

CourtSuperior Court of Maine
DecidedFebruary 12, 2016
DocketYORcv-15-269
StatusUnpublished

This text of Legrand v. Nadeau (Legrand v. Nadeau) 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
Legrand v. Nadeau, (Me. Super. Ct. 2016).

Opinion

STATE OF MAINE SUPERlOR COURT YORK, SS CIVIL ACTION DOCKETNO. CV-15-269

RENEE LEGRAND,

Plaintiff v. ORDER

ROBERT M.A. NADEAU, York County Probate Judge, et al.,

Defendants

Before the court are motions on behalf of York County and third party defendants

Gregory Zinser and Carol Lovejoy to dismiss the cross claims and third party claims asserted in

Judge Nadeau's Amended Answer. York County argues that the cross-claims against it do not

belong in this action and fail to state a claim. Third party defendants Zinser, who is the York

County Manager, and Lovejoy, who is the Register of Probate, contend that they have been

improvidently joined under M.R.Civ.P. 14 and that the third party complaint fails to state a

claim.

Oral argument was held on those motions on January 5, 2016. For the reasons set forth

below, Judge Nadeau's cross claim and his third-party claims are dismissed.

Count One of Cross Claim - Court Funding

In Count One of the cross-claim contained in Judge Nadeau' s Answer to the Amended

Complaint, Judge Nadeau is seeking injunctive relief requiring York County to provide "funding

. .. consistent with that of full time Maine judges" so as to comply with what he asserts is the

County ' s statutory obligation to ensure that the judicial functions of the probate court will be available and open to the public whenever other courts in Maine are open. Cross-Claim Count I,

"Wherefore Clause" (a). 1

Historically probate judges in Maine are different from other judges in that they are

elected and have always served on a part-time basis. In recognition of this, the Code of Judicial

Conduct provides that probate judges are excused from certain of the rules applicable to other

judges. See Code of Judicial Conduct, Coverage and Effective Date, § I.B(l ) (probate judges

required to comply with certain canons "only while serving as a judge"); § I.B(2) (probate judges

not required to comply with Rule 3 .10, which provides that judges may not practice law).

It has been contemplated that at some point probate judges will become full time, but that

has not yet happened. Art. VI, § 6 of the Maine Constitution provides for the election of the

judges in the existing Probate Court system. In 1967 Art. VI § 6 was repealed, with the repeal to

be effective "at such time as the Legislature by proper enactment shall establish a different

Probate Court system with full-time judges." See Amendment CVI; Chapter 77, Resolves of the

103rd Legislature, 1967. In the ensuing 49 years, the Legislature has not established a different

Probate Court System with full time judges.

Probate judges are also anomalous in that they are state officers even though they are

paid by the county. See Hart v. County of Sagadahoc, 609 A.2d 282, 284 (Me. 1992). Title 4,

M.R.S. § 301 states, "Judges of probate in the several counties are entitled to receive annual

salaries as set forth in Title 30-A, section 2." Although there is no longer a direct reference to

I In that count Judge Nadeau also seeks injunctive relief to obtain litigat ion defense insurance, more security staff, various security features , and a larger cou11room. The co urt understands that the issue of litigation insurance has now been resol ved because the State is providing Judge Nadeau with funding to retain outside counsel to defend the claims brought by plaintiffs . The other issues are controlled by the same principles as Judge Nadeau's general claim for more funding.

2 probate judge salaries in 30-A M.R.S. § 2, 2 the parties do not dispute that the salaries of probate

court judges are determined as part of the county budget.

How much to pay probate judges - which is partially a function of how many court days

per month they are expected to work as judges - is a non-justiciable issue. To the extent that

Judge Nadeau is seeking a judicial order that his position be made full -time, that would be

inconsistent with the constitutional amendment repealing Art. VI, § 6 once the Legislature

establishes a Probate Court with full-time judges, which it has not done.

Judge Nadeau bases his argument on 4 M .R.S. § 303, which states

Probate Court shall always be open in each county for all matters over which it has jurisdiction, except upon days on which by law no court is held, but it shall have certain fixed days and places to be made known by public notification thereof in their respective counties to which all matters requiring public notice shall be made returnable, except as otherwise ordered by the judge.

That statute, which has existed in some form since at least 1954, see R.S. 1954, c. 153 § 5, is not

a statutory command that probate judges are entitled to full time status. If it were, there would be

no reason to have postponed the repeal of Art. VI § 6. Read in its entirety, the statute simply

gives probate judges the flexibility to schedule their cases at any time, rather than confining their

work to fixed terms and preventing them from hearing evidence at any other times. See Estate of

Knapp, 145 Me. 189, 192, 74 A.2d 217, 219 (1 950).3

2 Until 1995, 30-A M.R.S § 2(1-B) specifically set the salary of the York County probate judge. For FY 1994, for example, that salary was$ 14,320 . See P.L. 1993, c. 653 § 2. In 1993 the Legislature approved the establishment of the York County Budget Committee, and legis lative approval of the York county budget was no longer required . P.L. 1993 c. 623. Thereafter 30-A M.R.S. § 2 was amended to delete any specific reference to the salary of the York County probate judge. P.L. 1995 c. 500 §1. 3 In other contexts, language that courts "s hall always be open" is intended to allow pleadings, documents, and court orders to be filed at any time. E.g, M.R.Civ.P. 77(a).

3 To the extent that Judge Nadeau is seeking additional payment based on the contention

that he needs additional court time to manage his docket, the court has no legal basis to interfere

in the budgetary and political decisions made by the County. This is true whether or not those

decisions are correct. Judge Nadeau has appended certain statistics as Exhibit C to his cross

claim, and those statistics demonstrate that at least based on 2014 budgetary figures, he is

currently the second highest paid probate judge in the state behind only the probate judge in the

state's most populous county.

Indeed, the determination of a probate judge's salary meets certain of the hallmarks of a

nonjusticiable "political question" - specifically

A lack of judicially discoverable and manageable standards for resolving [the issue]; or the impossibility of deciding without an initial policy determination of a kind clearly for nonjudicial discretion; or the impossibility of a court's undertaking independent resolution without expressing lack of the respect due coordinate branches of government ...

Baker v. Carr, 369 U.S. 186, 217 (1962). Salary and funding decisions with respect to probate

judges is an issue that the political branches of government, not the courts, must resolve.

This conclusion is consistent with the decision of the U.S. Court of Claims in Atkins v.

United States, 556 F.2d 1028 (Ct. Cl. 1977).

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Related

Baker v. Carr
369 U.S. 186 (Supreme Court, 1962)
Pulliam v. Allen
466 U.S. 522 (Supreme Court, 1984)
Forrester v. White
484 U.S. 219 (Supreme Court, 1988)
In Re Knapp's Estate
74 A.2d 217 (Supreme Judicial Court of Maine, 1950)
Palmer v. Portland School Committee
652 A.2d 86 (Supreme Judicial Court of Maine, 1995)
Marxsen v. Board of Dir., MSAD No. 5
591 A.2d 867 (Supreme Judicial Court of Maine, 1991)
Underwood v. City of Presque Isle
1998 ME 166 (Supreme Judicial Court of Maine, 1998)
Watt v. UniFirst Corp.
2009 ME 47 (Supreme Judicial Court of Maine, 2009)
Hart v. County of Sagadahoc
609 A.2d 282 (Supreme Judicial Court of Maine, 1992)
Lewiston Daily Sun v. School Administrative District No. 43
1999 ME 143 (Supreme Judicial Court of Maine, 1999)
Kennedy v. State
1999 ME 85 (Supreme Judicial Court of Maine, 1999)
Atkins v. United States
556 F.2d 1028 (Court of Claims, 1977)

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