Mulready v. Bd. of Real Estate Appraisers

CourtSuperior Court of Maine
DecidedMarch 9, 2009
DocketKENap-08-09
StatusUnpublished

This text of Mulready v. Bd. of Real Estate Appraisers (Mulready v. Bd. of Real Estate Appraisers) 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
Mulready v. Bd. of Real Estate Appraisers, (Me. Super. Ct. 2009).

Opinion

STATE OF MAINE SUPERIOR COURT CIVIL ACTION KENNEBEC, ss. DOCKET Nq. AP-P8~09 -- )(V)J~· Ii<~· \~- N - ::;!,-? .", ~"',~1 -<', i

ROBERT J. MULREADY

Petitioner

v. DECISION AND ORDER

BOARD OF REAL ESTATE APPRAISERS

Respondent

This case is before the court on petitioner's M.R. Civ. P. 80C petition for judicial

review of the Maine Board of Real Estate Appraisers (Board)'s finding that petitioner

violated the 2005 Uniform Standards of Professional Appraisal Practice (USPAP), and

the Board's imposition of professional discipline upon petitioner, including a formal

"warning" and hearing costs.

Facts

In August or September 2006, petitioner was employed by Dead River 80

Exchange Street, LLC (Dead River) to complete an appraisal of certain commercial

property in Bangor, Maine. This appraisal was undertaken in an effort to determine

whether Dead River could obtain an abatement of its taxes on the property.

By letter dated September 6,2005, petitioner wrote the Bangor City Tax Assessor

(Assessor), expressing his opinion that the property-originally assessed at $6,323,000­

was overvalued. Petitioner's letter indicated that he had been "retained by Dead

River," and Dead River separately notified the Assessor that petitioner was its "dilly

authorized agent" regarding the assessment of the property. On December 5,2005,

petitioner filed Dead River's Application for Abatement of Property Taxes with the City 2

of Bangor, indicating that Dead River's opinion of the current value of the property was

between $3,200,000 and $3,500,000. In support of Dead River's application, petitioner

met with the Assessor during the course of the next several weeks, providing a series of

reports, letters, and analyses regarding the valuation of Dead River's property, which

Petitioner estimated the fair market value to be $3,500,000.

On December 28,2005, the Assessor denied Dead River's abatement application.

In response, petitioner, on behalf of Dead River, filed an appeal with the Board of

Assessment Review (BOAR). Petitioner was also hired by Dead River to perform an

appraisal report and act as an expert witness before the BOAR. Petitioner's appraisal

report submitted to the BOAR concluded that the "just value" of the property was

$3,885,000.

On May 9, 2006, the BOAR granted an abatement of $983,600, finding that Dead

River had proven the property was substantially overvalued and that the original

"assessment was manifestly wrong."

Subsequently, on May 26,2006, Paul Linehan, on behalf of the Assessor, filed a

complaint with the Board, alleging that petitioner had acted as an "advocate" for Dead

River in the course of his appraisal services, and that petitioner's appraisal report

submitted to the BOAR contained several USPAP violations. After an evidentiary

hearing, the Board found that petitioner had committed two violations. First, the Board

found that petitioner was subject to discipline for violating a USPAP Ethics Rule

prohibiting an appraiser from advocating for a party or issue. See Me. Dep't of

Professional and Fin. Regulation, 02 298 CMR 240.1; USPAP Ethics Rule, 2005 ed. at 7.

Second, the Board found that petitioner was subject to discipline for violating a USPAP

Rule requiring that any appraisal report"contain sufficient information to enable the

intended users of the appraisal to understand the report properly." USPAP Standards 3

Rule 2-1(b), 2005 ed. at 22. Upon finding that petitioner committed these violations, the

Board voted to take disciplinary action, issuing petitioner a fonnal "warning" and

ordering him to pay $3,093.75 for hearing costs.

Standard of Review

When the decision of an administrative agency is appealed pursuant to M.R. Civ.

P. 80C, this court reviews the agency's decision directly for abuse of discretion, errors of

law, or findings not supported by the evidence. Centamore v. Dep't of Human Servs.,

664 A.2d 369,370 (Me. 1995). "An administrative decision will be sustained if, on the

basis of the entire record before it, the agency could have fairly and reasonably found

the facts as it did." Seider v. Bd. of Exam'rs of Psychologists, 2000 ME 206,

551,555 (Me. 2000) (citing CWCO, Inc. v. Superintendent of Ins., 1997 ME 226,

A.2d 1258, 1261 (Me. 1997)). The court will "not attempt to second-guess the agency on

matters falling within its realm of expertise" and judicial review is limited to

"detennining whether the agency's conclusions are unreasonable, unjust or unlawful in

light of the record." Imagineering, Inc. v. Superintendent of Ins., 593 A.2d 1050, 1053

(Me. 1991). "Inconsistent evidence will not render an agency decision unsupported."

Seider, 2000 ME 206,

seeking to overturn the agency's decision, and that party must prove that no competent

evidence supports the Board's decision. See Eischoff v. Ed. of Trustees, 661 A.2d 167,

170 (Me. 1995).

Discussion

Petitioner first argues that the Board's conduct violated his constitutional and

statutory rights. See U.s. Const. amend. XIV, § 1; Me. Const. art. I, § 6-A; Withrow v.

Larkin, 421 U.s. 35, 46-47 (1975); Zegel v. Ed. of Soc. Worker Licensure, 2004 ME 31,

16,843 A.2d 18,22 (stating that an "administrative process may be infirm if it creates an 4

intolerable risk of bias or unfair advantage"). See also 5 M.R.S. § 9063(1) (2007)

("Hearings shall be conducted in an impartial manner."). Specifically, petitioner takes

issue with several statements made by Bruce Bell, a member of the board, which

petitioner contends demonstrate bias and impermissibly infected the board's neutrality.

Until shown otherwise, this court must assume members of the Board to be fair

and capable. See In re Maine Clean Fuels, Inc., 310 A.2d 736, 751 (Me. 1973).

Nevertheless, bias exists where evidence indicates that the decision-maker has

"prejudged" the case. Cinderella Career & Finishing Schs., Inc. v. FTC, 425 F.2d 583,

589-92 (D.C. Cir. 1970). Here, although petitioner points to numerous statements made

by Mr. Bell to suggest evidence of bias, petitioner concedes that all such statements

were made after presentation of all the evidence. Read in context, these statements

merely demonstrated Mr. Bell's opinion-based on evidence presented-that petitioner

had committed certain USPAP violations.

Similarly without merit is petitioner's contention that the Board "reverse

engineered" their decision to impose a "warning," rather than a "letter of guidance" to

ensure petitioner paid costs. The Board is pennitted by statute to impose costs upon

"finding a violation." 10 M.R.S. § 8003-D (emphasis added). See also id. § 8003(5-A)(B).

Thus, regardless of whether the Board issued the petitioner a "letter of guidance" or a

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Related

Zegel v. Board of Social Worker Licensure
2004 ME 31 (Supreme Judicial Court of Maine, 2004)
In Re Maine Clean Fuels, Inc.
310 A.2d 736 (Supreme Judicial Court of Maine, 1973)
Centamore v. Department of Human Services
664 A.2d 369 (Supreme Judicial Court of Maine, 1995)
Bischoff v. Board of Trustees
661 A.2d 167 (Supreme Judicial Court of Maine, 1995)
Seider v. Board of Examiners of Psychologists
2000 ME 206 (Supreme Judicial Court of Maine, 2000)
CWCO, INC. v. Superintendent of Ins.
1997 ME 226 (Supreme Judicial Court of Maine, 1997)
Nyer v. Maine Unemployment Insurance Commission
601 A.2d 626 (Supreme Judicial Court of Maine, 1992)
Town of Sanford v. J & N SANFORD TRUST
1997 ME 97 (Supreme Judicial Court of Maine, 1997)
Imagineering, Inc. v. Superintendent of Insurance
593 A.2d 1050 (Supreme Judicial Court of Maine, 1991)

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