Liberty v. Liberty

CourtSuperior Court of Maine
DecidedOctober 30, 2002
DocketCUMcv-00-201
StatusUnpublished

This text of Liberty v. Liberty (Liberty v. Liberty) 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
Liberty v. Liberty, (Me. Super. Ct. 2002).

Opinion

Lé RO,

SUPERIOR COURT CIVIL ACTION

2002 oct POEKET NO. CV-00-201 Kac- C Wi} \ fu 7 Ob-f,

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STATE OF MAINE

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CUMBERLAND, ss. ,

DARLENE LIBERTY, Plaintiff DONALD L. GARBRECHT v. ORDER LAW LIBRARY SCOTT LIBERTY, DEC 3 am Defendant

a Set

Before this court is Darlene Liberty (Plaintiff)’s motion for injunctive relief. More specifically, the Plaintiff is asking this court to grant an order that would enjoin the Defendant and related parties from filing actions, motions or complaints, inter alia, before any judicial, administrative or other body without first obtaining the authorization of this court. Notably, the Plaintiff moved this court to enter an Order on April 2, 2002, decreeing that “tnleither party or their attorneys who represent them in this case are to file any further motions, pleadings, complaints and/or other documents in this case without first obtaining the prior approval of this Court.” Whereas that Order applied to both parties, the Plaintiff’s current motion essentially seeks to broaden the scope of the injunction as it pertains to the Defendant and related parties. From a jurisdictional standpoint the present matter is complicated by the fact that Scott Liberty (Defendant) has filed a Chapter 13 proceeding with the United States ' Bankruptcy Court. The Plaintiff's attorney is a creditor in the bankruptcy

proceedings.

ot The abovementioned Order was based on the principle that this court can use its equitable powers to “enjoin a party from filing frivolous and vexatious

lawsuits.” Spickler v. Key Bank of Southern Maine, 618 A.2d 204, 207 (Me. 1992).

In the present case the Plaintiff has the burden to “make a detailed showing of a pattern of abusive and frivolous litigation.” Id. The Plaintiff points out that the Defendant has engaged in a pattern of harassing and vexatious litigation tactics, which has resulted in driving up litigation costs along with emotionally taxing not only the Plaintiff, but also her family, her lawyer and her lawyer's family. For example, the Plaintiff estimates that the Defendant has filed in District and Superior Court at least eight motions to obtain a so-called sex videotape. The Defendant has also filed a variety of meritless complaints ranging from reporting the Plaintiff to the Maine Department of Human Services for endangering her children to reporting the Plaintiff's attorney to the Board of Overseers of the (Maine) Bar for professional misconduct. Having examined numerous pleadings, motions, transcripts, affidavits etc. contained in eighteen files, this court is well aware that a great deal of animosity has grown between the Defendant and the Plaintiff as well as the Defendant and the Plaintiff’s attorney. However, this “court must be careful not to issue a more comprehensive injunction than is necessary.” Id. The Plaintiff is requesting that this court screen any complaints the Defendant makes to such entities as the police, the Registry of Deeds, the United States Postmaster, and the federal courts. The holding in Spickler was limited to accessing the courts in Maine and not to other governmental entities or the federal system. See id. Moreover, the permanent injunction in Spickler was restricted to one of the parties and did not extend to

non-parties. See id. This court is wary of curtailing the Defendant’s freedom of speech. See U.S. CONST. amend. I (as it applies to the States through the Fourteenth Amendment); MAINE CONST. art. I §1. Furthermore, the difficulty with, say, restricting the Defendant's ability to file a complaint with the District Attorney is that this court would be thrust into the position of exercising prosecutorial discretion, which runs counter to the Legislature’s intentions. See 30-A M.R.S.A. § 283 (2002). On a more practical level, there is no mechanism, procedurally speaking or otherwise, for this court to stop the Defendant from pursuing a suit in the federal arena.

The Plaintiff has quoted Justice Selya for the proposition that a party has no right to perpetrate an “unconscionable scheme calculated to interfere with the judicial system’s ability impartially to adjudicate a matter by improperly

influencing the trier or unfairly hampering the presentation of the opposing

party’s claim or defense.” Aoude v. Mobil Oil Corp., 892 F.2d 1115, 1118 (1* Cir. 1989). Of course, Justice Selya was correct in his pronouncement. Nevertheless, the Aoude case can be distinguished in that it was concerned with a plaintiff perpetrating a fraud on the court by annexing a bogus purchase agreement to a complaint. See id. at 1117. Much of the Plaintiff’s present claim pertains to events that are occurring outside of the jurisdiction of this court. The Plaintiff goes on to point out that in another case involving divorce “[this] court acted within its discretion when it entered an order enjoining [one of the parties] from filing complaints, pleadings, or petitions against any individual involved in this litigation without the signature of a licensed attorney and the approval of a

judge.” Vogt v. Churchill, No. Mem 00-6 (Me. Jan. 24, 2000) (mem.) However,

per an order of the Law Court, this court cannot rely on a Memorandum Opinion

as proper authority.’ The Law Court has noted that the courts in Maine have historically taken a conservative approach when considering injunctive relief. See Bar Harbor

Banking & Trust Co. v. Alexander, 411 A.2d 74, 79 (Me. 1980) (quoting R.

WHITEHOUSE, EQUITY JURISDICTION § 563 (1900)). Hence, this court will only grant an injunction when there is no remedy at law and only when justice demands such relief. See id. In the present case, at least in dealing with the Plaintiff’s claims outside of this court’s direct jurisdiction, the Plaintiff and the Plaintiff’s attorney can avail themselves of such remedies at law as permitted by statute or case law. The Plaintiff argues that injunctive relief should be granted upon satisfying four criteria: (1) irreparable injury to the plaintiff, (2) the injury

outweighing the harm of the injunctive relief, (3) a likelihood of success on the

merits, (4) the public interest not adversely being affected. Dep’t of Envtl. Prot. v. Emerson, 563 A.2d 762, 768 (Me. 1989). However, this court has yet to be convinced that the broad scope of the relief being sought by the Plaintiff will not be outweighed by the harm such relief will cause the Defendant. Notwithstanding, this court is concerned with the fact that the Defendant has been convicted of crimes entailing extreme domestic violence. This court is. concerned with allegations of death threats being made. This court is particularly concerned that the animosity between the parties has reached the point where violence may ensue. Hence, this court will remind the attorneys

that they have an affirmative duty to not “directly or indirectly violate,

_ The Maine Law Court has issued an Order dated August 20, 1996 (No. SJC-216) advising that “Memorandum Decisions and Summary Orders shall not be published in the Atlantic Reporter and shall not be cited as precedent for any matter addressed therein.” _ circumvent, or subvert any provision of the Maine Bar Rules.” M. Bar. R. 3.1(f)(1). Accordingly, the attorneys shall immediately bring to the attention of this court any breach of duty owed to the court, the parties or to other attorneys.”

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Related

Salim Aoude v. Mobil Oil Corporation
892 F.2d 1115 (First Circuit, 1989)
Department of Environmental Protection v. Emerson
563 A.2d 762 (Supreme Judicial Court of Maine, 1989)
Bar Harbor Banking & Trust Co. v. Alexander
411 A.2d 74 (Supreme Judicial Court of Maine, 1980)
Spickler v. Key Bank of Southern Maine
618 A.2d 204 (Supreme Judicial Court of Maine, 1992)

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