McCarthy v. State of Maine

CourtSuperior Court of Maine
DecidedOctober 5, 2009
DocketKENap-08-44
StatusUnpublished

This text of McCarthy v. State of Maine (McCarthy v. State of Maine) 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
McCarthy v. State of Maine, (Me. Super. Ct. 2009).

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC, SS. CIVIL ACTION DOCKET NO. AP-:08·A4 r "' J ')-- "'-' ·'.r-1P f<~\r - 1(;;'-­ : DANIEL J. McCARTHY,

Petitioner

v. ORDER

STATE OF MAINE, DEPARTMENT OF SECRETARY OF STATE, BUREAU OF MOTOR VEHICLES

Respondent

This matter is before the court on petitioner's petition ("complaint") pursuant to

5 M.R.S.A. § 11001, et seq., and M.R. Civ. P. 80C. Petitioner avers that he is a Maine

resident whose occupation is repairing steam turbines in power plants throughout the

United States, necessitating his driving across the country. Petitioner explains that his

license to operate a motor vehicle was suspended as a result of a hearing with the

Bureau of Motor Vehicle. His license was ordered to be suspended on May 10, 2008.

The suspension was based on a finding that he was a habitual offender under Maine

law having ten or more convictions or adjudications for moving violations arising out of

separate acts committed within a five-year period. 29-A M.R.S.A. § 2551-A(1)(B).

Petitioner argues that the license suspension was not supported by substantial evidence

on the record in that it did not account for the fact that many of the moving violations

occurred out of state and before the effective date of this particular iteration of the

"habitual offender" legislation.

Petitioner argues that the respondent's decision represented an error of law and

violated the petitioner's constitutionally protected due process rights. The petitioner argues that he has been denied a property right by the denial of right to operate a motor

vehicle based upon ex post facto application of the habitual offender law.

Title 29-A M.R.S.A. § 2551-A(1)(B) provides:

1. Habitual offender defined. An habitual offender is a person whose record, as maintained by the Secretary of State, shows that:

B. The person has accumulated 10 or more convictions or adjudications for moving violations arising out of separate acts committed within a 5-year period.

The certified record reveals that as of April 15, 2008, petitioner had ten moving

violation convictions or adjudications in Maine, Virginia, New Jersey, New York,

Maryland, North Carolina, and Pennsylvania within a five year period.

The Maine Law Court has said that the statutory requirement rests upon the

premise that there is no absolute right to obtain and hold an operators license. It is

rather a privilege, which for valid reasons involving the public safety may be granted or

withheld by the State. It is true that the State may not unreasonably, arbitrarily, or

capriciously withhold a license, but it may properly condition the grant upon

compliance with reasonable police power requirements. Opinion of the Justices, 255 A.2d

643 (Me. 1969).

The United States Supreme Court has said that once licenses are issued, as in

petitioner's case, their continued possession may become essential in the pursuit of a

livelihood. Suspension of issued licenses thus involves State action that adjudicates

important interests of the licensees. In such cases the licenses are not to be taken away

without that procedural due process required by the Fourteenth Amendment. Bell v.

Burson, 402 U.s. 535, 91 S. Ct. 1586, 1589.

Title 29-A M.R.S.A. § 2551-A(1)(B) was enacted on August 23,2006. All but four

of petitioner's violations occurred prior to August of 2006. Accordingly, petitioner

2 argues that this constitutes ex post facto application of law which is constitutionally

prohibited, citing State v. Chapman, 685 A.2d 523, 524 (Me. 1996). This argument is best

addressed by the decision of the United States Supreme Court which said:

Nor do we think the fact that one of the convictions that entered into the calculations by which petitioner became a fourth offender occurred before the Act was passed, makes the Act invalidly retroactive or subjects the petitioner to double jeopardy. The sentence as a fourth offender or habitual criminal is not to be viewed as either a new jeopardy or additional penalty for the earlier crimes. It is a stiffened penalty for the latest crime, which is considered to be an aggravated offense because a repetitive one.

Gryger v. Burke, 334 U.S. 728, 68 S. Ct. 1256, 1258.

The due process as articulated by the Opinion of the Justices, 255 A.2d at 649, is a

standard that the State may not unreasonably, arbitrarily, or capriciously withhold a

license. In the present case, the petitioner was afforded all the processes that he was

due. He was informed of his right to appeal the decision of the Bureau of Motor

Vehicles that his license was being revoked, he appealed that decision, he had an

administrative hearing at which he appeared and testified, and he received a decision

and has received judicial review in this court.

Retroactive or retrospective laws are generally defined as "those which take

away or impair vested rights acquired under existing laws, or create a new obligation,

impose a new duty, or attach a new disability in respect to transactions or

considerations already passed." The statute is not retrospective merely because it

relates to antecedent facts or transactions to fix the status of a person, without changing

the legal effect of those prior transactions. Therefore, the statute does not create a new

obligation, impose a new duty, or attach a new disability to petitioner's conviction. It

relates to those convictions in order to fix petitioner's status under the act. Belanger v.

Quinn, 1980 Me. Super. LEXIS 21 Gune 17, 1980), citing Barbieri v. Morris, 315 S.W.2d 711,

714 (Mo. 1958); and State v. Scheffel, 82 Wn.2d 872, 514 P.2d 1052 (Wash. 1973), appeal

3 dismissed, 416 U.s. 964,401. Ed. 2d 554, 94 S. Ct. 1984 (1973). The court also notes that

previous versions of the habitual offender law contained a provision that no offenses

prior to the enactment of the statute should be considered. In the instant case, that

language does not appear.

In the absence of express language showing a contrary intent, statutes are to be

given perspective application. Opinion of the Justices, 370 A.2d 654, 668 (Me. 1977).

However, reliance upon a conviction occurring before the enactment of a habitual

offender law, to find one a habitual offender, is not a retrospective application of the

statute. Kelley v. Quinn, 1980 Me. Super. LEXIS 98 (Feb. 8, 1980); State v. Calloway,

236 Ga. 613, 225 S.E.2d 230 (Ga. 1976); Cappadona v. Keith, 290 So.2d 545 (Fla. 1974); State

v. Scheffel, 82 Wn.2d 872, 514 P.2d 1052 (Wash. 1973). If the Legislature had intended

that the statute only applied to offenses subsequent to its effective date, it could have so

provided. However, the express language of the statute demonstrates that the

Legislature intended that any conviction or adjudication which accrued in the past five

years could be used in determining habitual offender status. By using the past tense, it

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Gryger v. Burke
334 U.S. 728 (Supreme Court, 1948)
Bell v. Burson
402 U.S. 535 (Supreme Court, 1971)
Cappadona v. Keith
290 So. 2d 545 (District Court of Appeal of Florida, 1974)
State of Ga. v. Callaway
225 S.E.2d 230 (Supreme Court of Georgia, 1976)
State v. Scheffel
514 P.2d 1052 (Washington Supreme Court, 1973)
Barbieri Ex Rel. Barbieri v. Morris
315 S.W.2d 711 (Supreme Court of Missouri, 1958)
Aflalo v. Aflalo
685 A.2d 523 (New Jersey Superior Court App Division, 1996)
Opinion of the Justices of the Supreme Judicial Court
255 A.2d 643 (Supreme Judicial Court of Maine, 1969)
Opinion of the Justices
370 A.2d 654 (Supreme Judicial Court of Maine, 1977)

Cite This Page — Counsel Stack

Bluebook (online)
McCarthy v. State of Maine, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccarthy-v-state-of-maine-mesuperct-2009.