MacLean v. City of Portland

CourtSuperior Court of Maine
DecidedApril 8, 2022
DocketCUMcv-20-242
StatusUnpublished

This text of MacLean v. City of Portland (MacLean v. City of Portland) 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
MacLean v. City of Portland, (Me. Super. Ct. 2022).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss CIVIL ACTION DOCKET NO. CV-20-242 DAYID MacLEAN,

Plaintiff v. ORDER

CITY OF PORTLAND,

Defendant Plaintiff-Jonathan Goodman, Esq. Defendant-Anne Torregrossa, Esq.

Before the court is a motion for summary judgment by defendant City of Portland seeking

the dismissal of plaintiff David MacLean's complaint against the City under the Maine

Whistleblowers' Protection Act, 26 M.R.S. § 833(l)(A) & (B).

Summary Judgment

Summary judgment should be granted if there is no genuine dispute as to any material fact

and the movant is entitled to judgment as a matter of law. In considering a motion for summary

judgment, the court is required to consider only the portions of the record referred to and the

material facts set forth in the parties' Rule 56(h) statements. E.g., Johnson v. McNeil, 2002 ME

99 ,i 8, 800 A.2d 702. The facts must be considered in the light most favorable to the non-moving

party. Id. Thus, for pmposes of summary judgment, any factual disputes must be resolved against

the movant. Nevertheless, when the facts offered by a party in opposition to summary judgment

would not, if offered at trial, be sufficient to withstand a motion for judgment as a matter of law,

summary judgment should be granted. Rodrigue v. Rodrigue, 1997 ME 99 ,i 8, 694 A.2d 924. Discussion

Briefly stated, the City has offered evidence that MacLean was terminated from his

position as the City's Social Services Administrator for poor performauce. MacLean disputes the

City's evidence that his job performance justified termination. He contends that the adverse

employment action taken by the City instead resulted because of issues that he had raised in

internal discussions about the City's planning for a new homeless shelter - issues that he contends

involved potential violations of law.

Maine's Whistleblower Protection Act states in relevant part:

No employer may discharge ... an employee ... because: A. The employee, acting in good faith, or a person acting on behalf of the employee, reports orally or in writing to the employer or a public body what the employee has reasonable cause to believe is a violation of a law or rule adopted under the laws of this State, a political subdivision of this State or the United States; [or] B.... what the employee has reasonable cause to believe is a condition or practice that would put at risk the health or safety of that employee or auy other individual.

26 M.R.S. § 833 (l)(A), (B).

In this case MacLean specifically contends that he was subjected to adverse action because

(1) he had expressed the view that restricting the proposed homeless shelter to residents of the City

would be a violation of law, contravening an alleged statement by the City Mauager to the City

Council that a residency requirement would be permissible; and (2) he had objected to a decision

not to provide a legal memorandum on the residency issue that had been requested by the City

Council.

As an initial matter, although MacLean contends that the City Manager had informed the

City Council in November 2018 that residency requirements were permissible,1 the evidence he

1 See Plaintiffs Opposing Statement of Material Facts (OSMF) ,i,i 77, 105.

2 cites does not fully support that contention. The City Manager stated that he had recently been

informed that HUD and the Maine State Housing Authority did not object to residency

requirements. But he went on to state that there were still conversations to be had about General

Assistance - because General Assistance policy required the City to house individuals who

applied. Plaintiffs Ex. T, cited in Plaintiffs OSMF ,i 105.

MacLean has offered evidence that in response to the City Manager's statements, members

of the City Council requested a legal memorandum from the Corporation Counsel's office on the

residency issue. A draft memorandum was prepared in November 2018, in which the Corporation

Counsel concluded that the General Assistance statute required the City to provide emergency

general assistance benefits, including emergency shelter, without regard to residency.

A decision was made not to provide the memorandum to the City Council at that time. 2

The City has offered evidence that this happened because City officials thought the major issue to

be decided was the proposed location of the shelter and they did not want to distract the Council

with other issues until that had been resolved. MacLean, however, has offered evidence that in

meetings with City officials he stated that a residency requirement would violate the General

Assistance statute and that the Corporation Counsel's November 2018 legal memorandum should

be provided to the City Council. Whether the City Manager disagreed with those views and

whether MacLean's statements were met with an angry response from the City Manager are

disputed. 3

2 In revised fonn, but with the same conclusion, the memorandum was provided to the City Council in June 2019.

3 MacLean also says that he was concerned that a proposal to limit the proposed shelter to only 150 beds (apparently being considered by the City Council) would jeopardize the health and safety of homeless persons. MacLean has not offered evidence, however, sufficient to proceed with a Whistleblower claim

3 The City has argued that a hypothetical residency requirement, considered but never

formally proposed, cannot constitute the kind of violation of law that can sustain a claim under 26

M.R.S. § 833(\)(A). Considering the record in the light most favorable to MacLean as the party

opposing summary judgment, MacLean has offered evidence that he was opposing the City

Manager's alleged desire pursue an unlawful residency requirement. E.g., Plaintiffs OSMF ,r,r 92,

94, citing MacLean Aff. ,r,r 39-40. Accordingly, there is a disputed issue of fact for trial as to

whether MacLean was objecting to what he reasonably believed was a potential violation of law.

See Harrison v. Granite Bay Care Inc., 811 F.3d 36, 51-52 (1st Cir. 2016) (employee may be

whistleblower if acting "in opposition to" an unlawful practice). The Whistleblower statute should

be interpreted to protect employees opposing potential violations of law as well as existing

violations of law.

In addition, MacLean notes that under the City Administrative Code the Corporation

Counsel "shall, when requested, to do so by the City Council or any Committee thereof, ... furnish

written opinions on any subject relating to City affairs." 26 M.R.S. § 833(1)(A) embraces "a

violation of a law or rule adopted under the laws of . . . a political subdivision of this State"

(emphasis added). Accordingly, MacLean argues that the decision by City officials not to provide

the November 2018 legal memorandum to the Council also constituted a violation of law and that

his objection to that decision also constituted protected activity under the Whistleblower statute.

This may not be a particularly strong claim - because the memorandum was delayed but not

on that issue. See Pushardv. Riverview Psychiatric Center, 2020 ME 23 ,r 19-21, 224 A.3d 1239. It is undisputed that a 200 bed shelter was ultimately proposed.

4 withheld - but considered in the light most favorable to MacLean, it also raises a disputed issue

for trial. 4

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Related

Johnson v. McNeil
2002 ME 99 (Supreme Judicial Court of Maine, 2002)
Rodrigue v. Rodrigue
1997 ME 99 (Supreme Judicial Court of Maine, 1997)
Harrison v. Granite Bay Care, Inc.
811 F.3d 36 (First Circuit, 2016)
Darren Johnson v. York Hospital
2019 ME 176 (Supreme Judicial Court of Maine, 2019)
Roland Pushard III v. Riverview Psychiatric Center
2020 ME 23 (Supreme Judicial Court of Maine, 2020)

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MacLean v. City of Portland, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maclean-v-city-of-portland-mesuperct-2022.