Orr v. Town of Standish

CourtSuperior Court of Maine
DecidedDecember 1, 2011
DocketCUMcv-11-420
StatusUnpublished

This text of Orr v. Town of Standish (Orr v. Town of Standish) 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
Orr v. Town of Standish, (Me. Super. Ct. 2011).

Opinion

('10-/

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss. CIVIL ACTION DOCKET NO: CV-11/420 \.J fly) -C 1Ail1- \;:;;/ 1/t)OI/

WILLIAM ORR

Plaintiff,

v.

TOWN OF STANDISH ORDER Defendant, STATE OF MAINE Cumberland, ss, Clerk's Office

DEC 01 2011

RECEIVED Before the court is the defendant's 1 Motion to Dismiss the Complaint

under M.R. Civ. P. 12(b)(1) and 12(b)(6).

BACKGROUND The plaintiff, William Orr ("Plaintiff" or "Orr") filed a Complaint on

September 20, 2011 alleging a failure to comply with the Town of Standish

Charter, Ordinances, Codes and Maine Statutes regarding the subdivision of

land by the Town Manager and other elected town officials ("Defendant"). The

Plaintiff seeks to have a certain approved plan invalidated, testing of a road

constructed pursuant to the plan to confirm that it meets specifications, the Town

Manager's resignation without benefits, resignation of the chair of the Planning

Board, removal of the town planner, and "suspension of the Code Enforcement

Officer until such time he has been retrained on codes." (Compl. 10.)

1 The Plaintiff has captioned the action as "William Orr v. Town of Standish, Maine and Elected Officials, et al." The Plaintiff has not identified the elected officials included and he does not seek relief against any of these officials in their individual capacity. The real party in interest is the Town because the individual elected officials were acting in their official capacity.

1 The subdivision plan in question was first given preliminary approval in

January of 2006, with final approval coming in June of 2006. The applicants are

Gordon Billington, the Town Manager, and his wife Carol Billington, the Chair of

the Planning Board. 2 After final approval, it appears that the Planning Board

Administrator did not file the plan with the Cumberland County Registry of

Deeds within 15 days as required by section 181-85 of the Town of Standish Code

of Ordinances. Therefore, according to that section of code, the Planning Board's

approval of the plan became null and void 90 days after the approval was

granted. In January 2010, the applicants sought to amend the plan to bring it in

line with changes to the town ordinances occurring since final approval in 2006.

That application was approved and the updated plan was recorded in the

Cumberland County Registry of Deeds in Plan Book 210, Page 35. The Plaintiff

alleges that work on this subdivision began on January 8, 2011, is in violation of

the town ordinances because the original plan approval and the amendment are

nullities. 3 The Plaintiff also alleges that the acreage used to calculate the number

of lots approved is incorrect such that too many lots were approved and that

those lots are taxed at the woodland rate but should be taxed at the residential

rate.

In addition to the invalidation of the plan, the Plaintiff seeks to oust the

local government officials. He states:

2 There is no dispute that Carol Billington properly recused herself from all Planning Board action regarding her application for approval. 3 The Plaintiff alleges that approval for the plan expired three years after approval was granted. He cites to section 181-70.1 of the code of ordinances, which states that a site plan approval expires three years after approval was granted unless the applicant has made a substantial start. This section applies to site plan approvals not to subdivision plan approvals. However, based on the language in section 181-85, because the final approved plan was not recorded within 90 days of approval and no extension was given, it appears that the original plan is in fact null and void.

2 The point here is the Standish Town employees believe they are the government of the town and this attitude starts at the top with the Town Manger and prevails with many employees. They are to follow the same ordinances and laws as all the taxpayers are required to do and their job is to apply them. (Compl. 8.)

DISCUSSION

The purpose of a motion to dismiss is to test the legal sufficiency of the

complaint. McAfee v. Cole, 637 A.2d 463, 465 (Me. 1994). The court examines "the

complaint in the light most favorable to the plaintiff to determine whether it sets

forth elements of a cause of action or alleges facts that would entitle the plaintiff

to relief pursuant to some legal theory." Id. When testing the complaint under

M.R. Civ. P. 12(b)(6), the material allegations of the complaint must be taken as

admitted. Id. "Dismissal is warranted when it appears beyond a doubt that the

plaintiff is not entitled to relief under any set of facts that he might prove in

support of his claim." Johanson v. Dunnington, 2001 ME 169, 'IT 5, 785 A.2d 1244.

The Town of Standish ("Town" or "Defendant") filed a motion to dismiss

the complaint on the grounds that the Superior Court lacks subject matter

jurisdiction because it is time barred and on the grounds that the Plaintiff has not

stated a cause of action on which relief may be granted. 4 The Town is also

seeking legal fees from the Plaintiff for having filed a frivolous lawsuit in

violation of M.R. Civ. P. 11.

To the extent that the Plaintiff seeks to have the plan invalidated, he is

seeking review of governmental action. "Rule SOB is the sole means for seeking

Superior Court review of 'action' or 'failure or refusal to act' by any governmental

4 The Town also, as an affirmative defense raised in its answer, alleges insufficiency of process or insufficiency of service of process for failure to serve the complaint on the Town pursuant to M.R. Civ. P. 4(c) and 4(d)(5). The Town has not argued this affirmative defense in its motion to dismiss and seeks to preserve this defense.

3 agency, whether such review is specifically authorized by statute or is 'otherwise

available by law." Sold v. Town of Gorham, 2005 ME 24, CJI 13, 868 A.2d 172

(quoting Field, McKusick & Worth, Maine Civil Practice§ 80B.1 at 565 (Supp.

1981)). Under M.R. Civ. P. 80B(b) the time for filing a complaint for review of

government action under this rule is 30 days after notice of action or refusal to

act. The most recent action by the Planning Board occurred on January 4, 2010.

This Complaint was filed over 20 months later. Because time limits are

jurisdictional, the Plaintiff's failure to file a timely appeal of the Planning Board's

approval of this subdivision plan deprives this court of subject matter

jurisdiction.

At oral argument, the Plaintiff argued the town officials are not following

the town charter and that he is seeking a declaratory judgment that the town

charter is the "enforcing document." The court questions whether the Plaintiff

has standing to pursue this complaint. In Maine, standing is prudential rather

than constitutional, meaning that the courts may limit access to those who are

best suited to bring a particular claim. Lindermann v. Comm'n on Governmental

Ethics & Election Practices, 2008 ME 187, CJI 8, 961 A.2d 538. For a party to prove

that they are best suited to bring a claim, it must, at a minimum, demonstrate a

sufficient personal state in the controversy at the commencement of litigation.

Mortgage Electronic Registration Systems, Inc. v. Saznzders, 2010 ME 79, CJI 7, 2 A.3d

289. This requirement has also been articulated as requiring a "particularized

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Related

Ricci v. Superintendent, Bureau of Banking
485 A.2d 645 (Supreme Judicial Court of Maine, 1984)
Cimenian v. Lumb
2008 ME 107 (Supreme Judicial Court of Maine, 2008)
Lindemann v. Commission on Governmental Ethics and Election Practices
2008 ME 187 (Supreme Judicial Court of Maine, 2008)
McAfee v. Cole
637 A.2d 463 (Supreme Judicial Court of Maine, 1994)
Johanson v. Dunnington
2001 ME 169 (Supreme Judicial Court of Maine, 2001)
Mortgage Electronic Registration Systems, Inc. v. Saunders
2010 ME 79 (Supreme Judicial Court of Maine, 2010)
Sold, Inc. v. Town of Gorham
2005 ME 24 (Supreme Judicial Court of Maine, 2005)
Nergaard v. Town of Westport Island
2009 ME 56 (Supreme Judicial Court of Maine, 2009)

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Orr v. Town of Standish, Counsel Stack Legal Research, https://law.counselstack.com/opinion/orr-v-town-of-standish-mesuperct-2011.