Parenteau v. York County

CourtSuperior Court of Maine
DecidedNovember 4, 2002
DocketANDcv-02-134
StatusUnpublished

This text of Parenteau v. York County (Parenteau v. York County) 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
Parenteau v. York County, (Me. Super. Ct. 2002).

Opinion

STATE OF MAINE RECEIVED & FILED SUPERIOR COURT Androscoggin, ss. Civil Action . Ngy 04 2002 Docket No. CV-02-134

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Die Blip RANDY PARENTEAU, Personal SUPERIOR GOUT Representative of the Estate of

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LEANNE CAISSE, DECISION AND ORDER Plaintiff ON DEFENDANT’S v. MOTION TO DISMISS YORK COUNTY, Defendant DONALD L. GARBRECHT LAW LIBRARY I. BACKGROUND NOV 6 ae

Randy Parenteau is the personal representative of the Estate of Leanne Caissie. He brings this action against York County for the wrongful death of Caissie. © *

Dawn Welch, who is not a party to this action, was subject to house arrest during the Spring of 2001. Prior to being released on the home-release monitoring program, Welch was incarcerated for multiple offenses for operating a motor vehicle while under the influence of alcohol. At all times during her house arrest, the York County Sheriff's Department (“county” or “sheriff’) was responsible for monitoring Welch. 30-A M.R.S.A. § 1659 (Supp. 2001). On or about May 28, 2001, Welch had departed her home on a motorcycle with Caissie as a passenger. Welch hit a curb and a utility pole and Caissie was thrown from the bike, sustaining serious and ultimately fatal injuries. Welch had consumed alcohol at the time, in violation of her house arrest.

It is unclear from the complaint, but at some point the agency that was responsible for monitoring Welch via her electronic ankle bracelet notified the sheriff of the security breach (identified in the complaint as “sometime shortly before Welch and Caissie collided with the

pole”). Parenteau alleges the personnel assigned to take the call neglected to detain Welch ina timely fashion, in breach of the duty owed to plaintiff’s decedent. As a direct and proximate result of the breach of duty, the sheriff did not timely notify and dispatch deputies to intercept Welch before she harmed anyone and, ultimately her actions and the inactions of the sheriff, resulted in the untimely death of Caissie.

Parenteau further argues that the sheriff's failure to incorporate a written protocol for personnel to follow when faced with a situation such as the “escape” of Welch from her area of legal confinement constitutes neglect. He claims that the sheriff's personnel knew or had reason to know of the dangers in permitting a habitual offender to leave her legal confinement zone.

Plaintiff claims that the wrongful acts, neglect, or default of York County would have entitled, if death had not ensued, Caissie to maintain an action and recover damages. The Estate has suffered pecuniary injuries resulting from Caissie’s death and thus requests appropriate damages.

II. MOTION TO DISMISS

In response to the claim, the defendant has moved to dismiss pursuant to M.R. Civ. P. 12(b)(6). The essence of the motion is that the defendant is a governmental unit that enjoys the protection of governmental or sovereign immunity for the acts alleged and that they do not fall within any of the enumerated exceptions to the Maine Tort Claims Act. 14 M.R.S.A. § 8104-A.

III. DISCUSSION

A Motion to Dismiss under M.R. Civ. P. 12(b)(6) tests the legal sufficiency of the complaint. Seacoast Hangar Condominium II Assoc. v. Martel, 2001 ME 112, § 16, 775 A.2d 1166, 1171. A complaint that fails “to state a claim upon which relief can be granted,” must be dismissed. M.R. Civ. P. 12(b)(6). The court must presume the facts as set out in the complaint

and draw all inferences as may be reasonable in a light most favorable to the plaintiff. Herber v. Lucerne-in-Maine Village Corp., 2000 ME 137, J 7, 755 A.2d 1064, 1066. The plaintiff may prevail through a showing that the pleadings raise some factual issue that entitles the plaintiff to relief and denying in argument any facts asserted by the moving party that are not indicated in the complaint. Jd.

Because the county is a “governmental entity,” the Maine Tort Claims Act (MTCA) governs this action. 14 M.R.S.A. §§ 8101-8118 (Supp. 2001). The MTCA provides blanket immunity to governmental entities, which include by definition, counties. 14 M.R.S.A. § 8102(2), (3) (Supp. 2001). The MTCA provides four exceptions to general immunity, including liability for damage to property, bodily damage, or death. 14 M.R.S.A. § 8104-A. Governmental entities are exempt from (1) the negligent maintenance or use of vehicles;' (2) the negligent acts or omissions in the construction, operation or maintenance of any public building, or the appurtenances to any public building, not including discretionary function; (3) the negligent acts or omissions relating to the discharge of pollutants into or upon the land, the atmosphere, or any water course or body of water, but only to the extent that the discharge is “sudden” and “accidental;” and (4) the negligent acts of omission arising out of the performance of road construction, street cleaning, or repair. Jd § 8104-A(1)-(4).°

Immunity may be waived if the governmental agency obtains insurance providing coverage in areas where the entity normally enjoys immunity. City of Old Town v. Dimoulas, 2002 ME 133, 4 25, 803 A.2d 1018, 1025. However, the Law Court, has held that if the policy is

limited to coverage for “those areas for which governmental immunity has been expressly

' “Vehicles” include machinery and equipment of any motor vehicle, special mobile equipment, trailers, aircraft, watercraft, snowmobiles, or other machinery. 14 M.R.S.A. § 8104-A(1)(A)-(G).

* The governmental entity is also liable for the maintenance and use of a building whether acquired through tax sale or eminent domain. /d. § 8104-A(2)(B), (C).

> Only the first exception is applicable to this case. waived pursuant to specified provisions, and also provided that ‘[I]iability coverage shall not be deemed a waiver of any immunities or limitation of damages available under the Maine Tort Claim Act, or other Maine statutory law, judicial precedent or common law.’” City of Old Town v. Dimoulas, 2002 ME 133, 4 25, 803 A.2d 1018, 1025 (citing Doucette v. City of Lewiston, 1997 ME 157, Jf 8-10, 697 A.2d 1292, 1294); see also 14 M.R.S.A. § 8116. Compared to the policy approved by the Law Court in Doucette, the language in the county’s policy is verbatim.

The county argues that Parenteau’s claims do not fall within any of the enumerated exceptions to immunity under the MTCA. It is correct. The Law Court routinely interprets the immunity exceptions under the MTCA narrowly; and thus, the exceptions may not be broadened to include the type of harm alleged in the instant case.

The Law Court recently issued a decision that demonstrated its commitment, narrowly construing § 8104-A. In Thompson v. Dep’t of Inland Fisheries & Wildlife, 2002 ME 78, 796 A.2d 674, the plaintiff, a recreational snowmobiler required medical evacuation via helicopter from a trail maintained by the Department of Inland Fisheries and Wildlife. /d. 1, 796 A.2d at 674. Thompson claimed the State failed to sufficiently fuel a helicopter and maintain adequate communication and navigation equipment. Jd. § 2, 796 A.2d at 675. As such, he argued, the State was liable for negligence, falling “squarely” within the plain meaning of “ownership, maintenance or use” of vehicles.” Jd. | 5, 796 A.2d 676; see also 14 M.R.S.A. § 8104-A(1).

The Law Court upheld the dismissal by the Superior Court Jd. § 9, 796 A.2d at 677. The Court stated that “[i]n interpreting section 8104A(1), therefore, the focus is on the risk of harm naturally or directly caused by the vehicle’s contact with the general public.” Jd. § 7,796 A.2d at 677. As with prior claims of negligence under subsection A(1), the Law Court found that the

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Parenteau v. York County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parenteau-v-york-county-mesuperct-2002.