Nate Holyoke Builders v. Maine Workers' Compensation Bd.

CourtSuperior Court of Maine
DecidedJuly 17, 2013
DocketKENap-12-12
StatusUnpublished

This text of Nate Holyoke Builders v. Maine Workers' Compensation Bd. (Nate Holyoke Builders v. Maine Workers' Compensation Bd.) 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
Nate Holyoke Builders v. Maine Workers' Compensation Bd., (Me. Super. Ct. 2013).

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC, SS. CIVIL ACTION DOCKET NO. AP-12-12 J) l-IM- ~[j'vl_. 7j /, 7/~"J r:; f .j NATE HOLYOKE BUILDERS et al.,

Plaintiffs v. ORDER

MAINE WORKERS' COMPENSATION BOARD,

Defendant

Before the Court is Defendant Maine Workers' Compensation Board ("WCB") motion to

dismiss Plaintiff Nate Holyoke Builders, Inc.'s ("NHB") complaint for declaratory and

injunctive relief pursuant to Rule 80C and 42 U.S.C. § 1983. Because the Plaintiff cites Rule

80C in its complaint, the Defendant seeks dismissal on the ground that there is no final agency

action as a jurisdictional impediment. See Tomer v. Me. Human Rights Comm 'n, 2008 ME 190,

~ 14, 962 A.2d 335 (requiring dismissal because the court lacked subject matter jurisdiction).

The motion further argues that the appropriate forum for appellate review is the Law Court after

a decision issued by the Defendant. The Defendant further asserts in its motion that the

complaint fails to state a claim for which relief can granted to the extent that Plaintiff seeks

review in the underlying administrative proceeding in which the action is time barred.

Defendant's motion further goes on to argue that the Plaintiff fails to comply with M.R. Civ. P.

80C(i). Finally, the Defendant asserts that the Plaintiff cannot claim relief under 42 U.S.C.

§ 1983 on due process grounds and on the basis that the Legislature has established a process for

review that is adequate to address the claims. Defendant argues that a state law remedy is adequate and the Plaintiff fails to identify a protected property interest and other due process

violations.

Notwithstanding the title of the complaint as a "Complaint for Declaratory and Injunctive

Relief Pursuant to Rule 80C and 42 U.S.C. § 1983," the language of the complaint does not

invoke a petition for judicial review under Rule 80C. Accordingly, the underlying matter before

the Court is a complaint for declaratory judgment and injunctive relief and due process claims

under 42 U.S.C. § 1983. Therefore, the Court will not respond to Defendant's arguments that the

Plaintiff has failed to comply with the terms of M.R. Civ. P. 80C.

Plaintiff points out that it is a Maine business corporation performing as a general

contractor in the construction of residential homes. It asserts that at all relevant times it has been

the named insured under Workers' Compensation and Employers Liability Insurance policies

issued by various insurers, and by specifically identifying three policies. The complaint states,

The WCB has admitted in the pending adversarial matter it commenced against Nate Holyoke Builders that the workers' compensation policies issued to Nate Holyoke Buildings and in place at all times material to this matter in fact would be required to respond and pay workers' compensation benefits to any person found to be an employee ofNate Holyoke Builders entitled to such benefits, even if that employee was unknown to the workers' compensation insurer or had previously been issued a decision by the WCB granting that person a predetermination status as an independent contractor.

Plaintiff goes on to explain Maine Bureau of Insurance Regulation, Chapter 4 70, which

outlines the process of conducting an audit and advising the insured employer that additional

premium is owed. It recites 39-A M.R.S.A. § 401(1) and (3) as the law regarding the

requirement of the Plaintiff to comply and ensures that at all times material to the complaint and

the administrative proceeding it had the appropriate workers' compensation insurance policies.

2 And further, as to this Plaintiff, the WCB had issued multiple decisions granting

predetermination of independent contractor status.

In October 2010, the WCB notified the Plaintiff that it would conduct an audit to verify

compliance with the insurance coverage requirement of the Workers' Compensation Act. After

completion of the audit, the WCB auditor issued a report titled, "Employee Misclassification

Audit Report" dated December 8, 2010 (the "Audit Report"). The Audit Report indicated that

Plaintiff may have misclassified employees as independent contractors and sought verification.

It is alleged that the Audit Report was kept confidential by the WCB and neither the Audit

Report nor its contents were provided to the Plaintiff for almost one year. Finally, the complaint

alleges that subsequent to the Audit Report, "the WCB issued new decisions granting and

reaffirming predeterminations of independent contractor status to every subcontractor who

sought such determination and who the WCB had previously identified in the Audit Report as

possibly misclassified."

In its prayer for relief, Plaintiff asserts that the WCB does not have jurisdiction under

sections 324(3), 401, and 403 to collect additional premiums, and the workers are entitled to an

order enjoining the WCB from engaging in the collection activity. In its second prayer, the

Plaintiff alleges denial of due process under 42 U.S.C. § 1983, and Article I, section 6-A of the

Maine Constitution. In this prayer it seeks attorney fees and costs and alleges that the WCB

made decisions determining error in the predetermination status without disclosure to the

Plaintiff. Finally, in its third prayer, the Plaintiff asks the Court to estop the Defendant from

imposing sanctions against it.

Dismissal is proper if the complaint fails to state a claim upon which relief can be

granted. M.R. Civ. P. 12(b)(6); Shaw v. S. Aroostook Cmty. Sch. Dist., 683 A.2d 502, 503 (Me.

3 1996). The Court reviews the complaint in the light most favorable to the plaintiff to ascertain

whether the elements of a cause of action are properly set forth, and accordingly, "the material

allegations of the complaint must be taken as admitted." Livonia v. Town of Rome, 1998 ME 39,

~ 5, 707 A.2d 83. The Court should dismiss a claim only "when it appears 'beyond doubt that

[the] plaintiff is entitled to no relief under any set of facts that [it] might prove in support of [its]

claims."' McAfee v. Cole, 637 A.2d 463, 465 (Me. 1994) (quoting Hall v. Ed. of Envtl. Prot.,

498 A.2d 260, 266 (Me. 1985) ). The sufficiency of a claim pursuant to Rule 12(b )( 6) is a

question of law. See Bowen v. Eastman, 645 A.2d 5, 6-7 (Me. 1994 ). Last, "[ w ]hen a motion to

dismiss is based on the court's lack of subject matter jurisdiction, we make no favorable

inferences in favor of the plaintiff such as we do when reviewing a motion to dismiss for failure

to state a claim upon which relief can be granted." Tomer, 2008 ME 190, ~ 9, 962 A.2d 335.

As a threshold matter, it should be noted that no § 1983 claim can be brought against the

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