Martin v. Maine Plumbers' Examining Board

CourtSuperior Court of Maine
DecidedOctober 4, 2021
DocketKENap-21-12
StatusUnpublished

This text of Martin v. Maine Plumbers' Examining Board (Martin v. Maine Plumbers' Examining Board) 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
Martin v. Maine Plumbers' Examining Board, (Me. Super. Ct. 2021).

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC, SS. CIVIL ACTION DOCKET NO-AP-21-12

RICHARD P. MARTIN, Petitioner DECISION AND ORDER V.

MAINE PLUMBERS' EXAMINING BOARD, Respondent

INTRODUCTION Richard P. Martin (Martin), a master plumber, has appealed from a Decision and Order dated March 8, 2021, from the Maine Plumbers' Examining Board (Board) that imposed discipline against him after finding that he had violated the Maine Plumbing Code, had demonstrated incompetence in the practice of plumbing and had violated the standards of practice as a plumber. The appeal has been filed pursuant to 5 M.R.S. §§ 11001-11002 (Maine Administrative Procedure Act) and M.R.Civ.P. SOC. Martin contends that the Board committed error requiring reversal of its Decision and Order because: ( 1) the Notice of Hearing provided to him violated his Due Process rights by failing to adequately notify him that he was alleged to have been incompetent or to have violated the standards of practice expected of a plumber; (2) no expert testimony was presented to establish his incompetence or violation of the standards of practice, and; (3) the Board considered uncharged and unadjudicated conduct, and facts not in evidence, when it imposed sanctions against him, and failed to adequately explain why it imposed those sanctions. FACTUAL AND PROCEDURAL BACKGROUND Following an adjudicatory hearing held on December 14, 2020, the Board voted to find that Martin had committed 8 violations of the Maine Plumbing Code, and further found, based on those violations, that Martin had demonstrated incompetence in the plumbing profession and had violated the standards of practice within that profession, in connection with his work on a project in Harrison in the Fall of 2019. The Board voted to impose discipline on the 8 Plumbing Code violations only, which discipline consisted of the following: ( 1) a civil penalty of $1,000 per violation, for a total civil penalty of $8,000; (2) suspension of Martin's Master Plumber's license for 1 month per violation, for a total suspension of 8 months, and; (3) probation for 2 months per violation for a total probationary period of 16 months, subject to the condition that he submit copies of all permits obtained by him to the Board's designee within 24 hours. (R. at 6). The Notice of Hearing provided to Mr. Martin set forth the eight specific provisions of the Plumbing Code he was alleged to have violated, and further stated that those alleged "violations ... constitute incompetence," and "a violation of standards of practice." (R. at 9). In response to the complaint filed against him by the Senior Plumbing Inspector, and at the adjudicatory hearing held on December 14, 2020, Mr. Martin did not dispute and, in fact, acknowledged that he was responsible for violating the Plumbing Code as alleged. During the hearing, it was revealed by Mr. Martin that the two workers he assigned to the job in question were unlicensed and that he had not always supervised them during their work on the project. No expert testimony was

2 presented, but the specific provisions of the Plumbing Code alleged to have been violated by Mr. Martin were admitted into evidence without objection. (R. at 36, Exhibit 6). During her closing argument before the Board, the Assistant Attorney General presenting the case in support of the complaint maintained that the evidence showed that Mr. Martin had violated multiple provisions of the Plumbing Code which, it was asserted, demonstrated incompetence on his part and that he had violated the standards of practice for a plumber. (R. at 67 et seq.). Moreover, referring to the information disclosed by Mr. Martin during his testimony that he had used unlicensed and unsupervised workers at the job site, the Assistant Attorney General argued that the Board should find Mr. Martin responsible and sanction him accordingly. (Id.). Martin, through counsel, objected and moved for dismissal of the complaint. (R. at 68). With respect to any argument that Martin was incompetent or had violated the standards of practice, the hearing officer allowed the AAG to continue with her argument after ruling that those two allegations were contained in the Notice of Hearing. 1 (R. at 67-68). Regarding any reference to Martin's use of unlicensed works who were not properly supervised, the hearing officer ruled that such evidence was admissible for consideration by the Board, but it could not be used as a new and separate allegation of misconduct. At the close of all the evidence, the three Board members began their deliberations. At various point, some members strayed from the liability

1 It is true that the hearing officer was initially unsure as to whether those allegations were part of the Notice of Hearing, but after reviewing the notice, she ruled that they were. (R.at 67-68).

3 phase into the sanctions phase of their deliberations. 2 Whenever that happened, however, the hearing officer promptly redirected the Board members and provided them with appropriate limiting instructions. (R. at 70­ 74). After the Board had voted to find that Martin had committed the eight specific violations of the Plumbing Code, and that he had thereby acted in an incompetent manner and in violation of the standards of practice for a plumber, the hearing officer advised the Board that, for purposes of imposing sanctions, the Board should limit itself to the eight Plumbing Code violations so as not to "double count" the violations. (R. at 73). The Board followed that advice and imposed discipline against Mr. Martin for the eight Plumbing Code violations only. STANDARD OF REVIEW The Law Court has frequently reaffirmed the principle that judicial review of administrative agency decisions is "deferential and limited." Passadumkeag Mountain Friends v. Bd. OfEnvtl. Prat., 2014 ME 116, , 12, 102 A.3 d 1181 ( quoting Friends ofLincoln Lakes v. Bd. OfEnvtl. Prof., 2010 ME 18,, 12, 989 A.2d 1128). The court is not permitted to overturn an agency's decision "unless it: violates the Constitution or statutes; exceeds the agency's authority; is procedurally unlawful; is arbitrary or capricious; constitutes an abuse of discretion; is affected by bias or error of law; or is unsupported by the evidence in the record." Kroger v Departmental of Environmental Protection., 2005 ME. 50,, 7, 870 A.2d 566. The party seeking

2 This may be explained, at least in part, by the fact that a copy of Mr. Martin's prior discipline by the Board in 2006 was admitted into evidence as part of the prosecution's case-in-chief, for the purpose of supporting the allegation of incompetence and as being relevant on the issue of sanctions, in the event the Board got to that issue. (R. at 63 and 44, 48-49: Exhibits 7 & 9).

4 to vacate a state agency decision has the burden of persuasion on appeal. Anderson v Maine Public Employees Retirement System, 2009 ME. 134, ,r 3, 985 A.2d 501. A party seeking to overturn an agency's decision bears the burden of showing that "no competent evidence" supports it. Stein v. Me. Crim. Justice Academy, 2014 ME 82, ,r 11, 95 A.3d 612. DISCUSSION A. Did the Petitioner Receive Fair Notice? Martin complains that he did not receive constitutionally adequate notice that he was being accused of incompetence and violating the standards of practice for plumbers. The court does not find this argument persuasive. The Notice of Hearing sent to Martin specifically cited 10 M.R.S. § 8003(5-A)(A)(2), which states in pertinent part that the Board may impose discipline for "incompetence ... or violation of any applicable ... standards of practice while engaged in the occupation or profession for which the person is licensed." The notice expressly informed Martin that he was alleged to have violated the Plumbing Code.

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Bluebook (online)
Martin v. Maine Plumbers' Examining Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/martin-v-maine-plumbers-examining-board-mesuperct-2021.