McKinney v. Town of Eliot

CourtSuperior Court of Maine
DecidedDecember 26, 2007
DocketYORap-07-029
StatusUnpublished

This text of McKinney v. Town of Eliot (McKinney v. Town of Eliot) 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
McKinney v. Town of Eliot, (Me. Super. Ct. 2007).

Opinion

STATE OF MAINE SUPERIOR COURT CIVIL ACTION YORK, ss. .DOCKET NO. AP-07-049 bt\f; -' ~ 0 p.:~- I /fIle) Ie> ~ cy'y , J

MICHAEL E. MCKINNEY and CAROLYN A. MCKINNEY,

Plaintiffs

v. ORDER

TOWN OF ELIOT,

Defendant

This matter comes before the Court on Defendant Town of Eliot's (Town) Motion

to dismiss Plaintiffs Michael E. McKinney and Carolyn A. McKinney's (the

UMcKinneys") complaint pursuant to M.R. Civ. P. 80B. The Court is also scheduled to

hear the merits of the McKinneys' Rule 80B appeal.

PROCEDURAL HISTORY

The facts of this case are largely undisputed. The McKinneys filed two 80B

appeals in this Court with respect to a variance and waiver granted by the Town to the

American Legion Post (American Legion) located on Main Street in Eliot, Maine. 1 On

February 26, 2007, both appeals were remanded to the Eliot Zoning Board of Appeals

(ZBA) for failure to make the sufficient and clear finding of facts necessary for judicial

review.

1 The variance and waiver were granted for the benefit of Ethel's Tree of Life (TOL), which runs a transitional training program for special needs children and young adults. TOL utilizes space in the American Legion. In compliance with the remand, the ZBA held a meeting on May 17, 2007 in

order to reissue findings of fact sufficient for judicial review (Appeal Meeting). The

McKinneys attended the Appeal Meeting. On July 6, 2007, approximately 50 days after

the Appeal Meeting, the McKinneys again filed an appeal with this Court asserting that

the "finding of facts at the May 17, 2007 meeting failed to meet the Court's ruling to

make specific findings."

The Town moves to dismiss the claim as untimely filed and further asserts that

the McKinneys have failed to state a claim upon which relief can be granted?

DISCUSSION

1. Plaintiffs' 80B Appeal

A. Factual Background

Before the Court is an appeal of the finding of facts of the Town's Zoning Board

of Appeals ("ZBA") made on May 17, 2007 pursuant to this Court's remand of the

McKinneys' previous appeal. At issue in this second appeal is whether the ZBA's

decision is supported by the sufficient and clear findings of fact necessary for judicial

review based on the evidence in the record.

B. Standard of Review

Review of the Board of Appeals' findings is "for an abuse of discretion, error of

law, or findings unsupported by substantial evidence in the record." O'Toole v. City of

Portland, 2004 ME 130, <][8, 865 A.2d 555, 558. This Court is "limited to determining

whether the record contains evidence to justify the Board's determination." Lewis v.

2 While the Town's Motion to Dismiss on timeliness grounds may be dispositive, I proceed to the merits of the SOB appeal because I failed to expressly retain jurisdiction on remand. This, no doubt, created confusing procedural problems for the Plaintiffs, who represented themselves throughout these proceedings.

2 Maine Coast Artists, 2001 ME 75, <[14, 770 A.2d 644, 650. The party appealing the zoning

board's decision bears the burden of persuasion. Twigg v. Town of Kennebunk, 662 A.2d

914, 916 (Me. 1996).

By statute, a zoning board is required to provide not only a statement of its

findings of fact and conclusions of law, but also "the reasons or basis for the findings

and conclusions." 30-A M.R.S. § 2691(3)(E) (2005). Adequate findings of fact are crucial

to the Court's review a zoning board's action under Rule 80B because "[m]eaningful

judicial review of an agency decisions is not possible without findings of fact sufficient

to apprise the Court of the decision's basis." Chapel road Associates, LLC v. Town of Wells,

2001 ME 178, <[ 9, 787 A.2d 137, 140.

C. Conditional Use Permit

The ZBA granted a conditional use permit to TOL based on the conclusion that

the existence of TOL at the American Legion would not create increased intensity of use

or traffic safety issues at the American Legion. On remand, the ZBA was directed to

support that conclusion with specific findings of fact.

At the Appeal Meeting, the ZBA took additional testimony and considered

testimony previously taken regarding the McKinneys' appeals. The ZBA found inter

alia that:

1. TOL uses the American Legion primarily for administrative purposes with two or three people present; 2. Occasionally the number is higher, but they arrive by van and the impact is similar to American Legion events; 3. TOL uses carpooling rather than individual cars; 4. American Legion meetings usually mean more cars utilizing the parking spaces; 5. The American Legion has rented the space in the past for various activities that have "brought in additional traffic." 6. TOL and the American Legion would not use the facility concurrently.

Town of Eliot Board of Appeals Meeting - May 17, 2007 p. 15-16.

3 Based upon these findings, the Town asserts that TaL is not a "new use" or

expansion of use as defined in Article X of its ordinance, and consequently is not subject

to Article X's parking requirements. 3 The record evidence supports this finding.

D. Waiver and Variance

Before granting a varience, the ZBA must consider the following criteria: (1) the

land would not earn a reasonable return absent a variance, (2) a variance is needed due

to unique circumstances and not the general character of the neighborhood, (3) the

variance would not change the essential character of the area, and (4) the hardship was

not caused by the actions of the proponent or a prior owner. 30-A M.R.S.A. § 4353(4)(a)­

(D) (2005).

a. Reasonable Return Absent a Variance

On remand, the ZBA was required to articulate finding of facts regarding

whether or not the land would earn a reasonable return absent a variance. The ZBA

found inter alia that:

1. The American Legion holds the property by a deed containing a reverter clause. Consequently, if the American legion cannot stay in operation, the property will revert to the Town. 2. The American Legion treasurer testified that the American legion cannot support the building by itself. It is dependent on the revenue generated by TaL. If TaL is not allowed to rent the space, the American Legion will have to close. 3. Should the property be put to a new use, parking spaces in accordance with the ordinance would be required.

Town of Eliot Board of Appeals Meeting - May 17, 2007 p. 17.

3 The scope of Article X is defined under the ordinance as:

The standards in this article shall apply to all new uses or establishments which expand or increase their volume or intensity of usage. They shall also apply to all new or expanded parking facilities.

4 b. Unique Circumstances

With respect to the unique circumstances surrounding this property, the ZBA

found that:

1. The property was a small corner lot; 2. The building took up substantially all of the lot, save the residential setback requirements and there is no physical room for additional parking in compliance with the ordinance; 3. The lot is uniquely encumbered by a reverter clause to the Town.

c. No Change to Essential Character of the Area

The ZBA found that the essential character of the area would remain unchanged

based upon:

1.

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Related

Twigg v. Town of Kennebunk
662 A.2d 914 (Supreme Judicial Court of Maine, 1995)
Chapel Road Associates, L.L.C. v. Town of Wells
2001 ME 178 (Supreme Judicial Court of Maine, 2001)
Lewis v. Maine Coast Artists
2001 ME 75 (Supreme Judicial Court of Maine, 2001)
O'Toole v. City of Portland
2004 ME 130 (Supreme Judicial Court of Maine, 2004)

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McKinney v. Town of Eliot, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mckinney-v-town-of-eliot-mesuperct-2007.