Parsons v. Inhabs. of the Town of Carmel

CourtSuperior Court of Maine
DecidedJune 17, 2002
DocketPENap-02-2
StatusUnpublished

This text of Parsons v. Inhabs. of the Town of Carmel (Parsons v. Inhabs. of the Town of Carmel) 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
Parsons v. Inhabs. of the Town of Carmel, (Me. Super. Ct. 2002).

Opinion

_ HT ALD L. GAREREC DONALD LS

STATE OF MAINE FEB 25 2002 _ SUPERIOR COURT

PENOBSCOT, SS. Docket No. AP- 02- 2 JL ME ay = oa A002

Sharrlyn B. Parsons et al!, °

Plaintiffs

Vv. ORDER

FILED AND ENT SUPERIOR COURT.

Inhabitants of the Town FEB 21 2067

of Carmel et al.,

Defendants PENOBSCOT COUNTY

Pending before the court is the plaintiffs' motion for preliminary injunction. Hearing on the motion was held on February 20, 2002. The parties were present with counsel. The court has considered the record evidence, the parties’ oral presentations and their written arguments.

Plaintiff Sharrlyn B. Parsons was involved in circulating a petition among residents of Carmel. The purpose of the petition was to include an article in the warrant for the town meeting scheduled for March 4, 2002. The proposed article had several components that related to an ongoing dispute between the Town of Carmel and plaintiff Earle McSorley. That dispute, which generated significant litigation in both of Maine's trial - courts and in the Law Court, centered on McSorley's legal obligation to establish a proper grade along that portion of the Horseback Road abutting his land, which, at least in part, is a gravel pit. The article would create an acknowledgement that plaintiff Earle McSorley had "labored extensively"

in efforts to make a portion of the Horseback Road safe for travel; it would

]

deem the installation of a guardrail to complete the process by which the Horseback Road would be made safe for traffic; it would prohibit the Town from engaging in any further court proceedings (including collection of attorney's fees, forfeitures and penalties); it would require the Town to return to McSorley any real property that the Town had acquired in its efforts to enforce prior court orders; and it would require the Town to dismiss with prejudice any claims pending McSorley and his wife that related "in any way" to the Horseback Road dispute.

Ultimately, enough signatures were collected to Satisfy the quantitative requirements of 30-A M.R.S.A. § 2522. Parsons submitted the petitions to the Town. At a meeting held on December 17, 2002, the Town's Board of Selectmen ("the Board") decided that the article associated with the petition would not be included in the warrant for the March 4 town meeting. McSorley's wife is one of the Town's selectmen! and advised her husband that evening of the Board's decision. Parsons learned on December 21 that the Board had decided to reject the proposed article from inclusion in the warrant for the upcoming town meeting.”

On January 22, 2002, Parsons and McSorley filed the pending

1She abstained from voting at the selectmen's meeting when the petition issue was addressed.

2The evidence generated a factual dispute about when Parsons received notice

of the Board's decision. The Town Manager testified that on December 18 he verbally advised her of the decision and then wrote a letter dated December 19. The text of the letter, however, does not make reference to any verbal notification, and one might expect such a letter to do so. Parsons, on the other hand, testified that she did not receive any notice of the Board's decision until December 24. This contradicts the allegation in her complaint that she received that notice on December 21. See complaint at | 9. The best evidence indicates: -- and the court finds -- that she received that notice on December 21, as she alleged. This is generally consistent with the transmission of a letter on December 19, if one allows a day or two for mailing.

2 complaint, seeking an order requiring the Town to include the proposed article in its warrant for the March 4 town meeting. A. Jurisdiction

Although not raised by the parties, this action raises a question of whether the court has jurisdiction to entertain the merits of the plaintiffs’ argument.? Jurisdictional issues may be considered on the court's own notice. Hodsdon v. Town of Hermon, 2000 ME 181, { 3, 760 A.2d 221, 222.

The plaintiffs have presented their complaint as an appeal under M.R.Civ.P. 80B. The complaint itself is labelled generically as a complaint, and the prayer for relief is framed in terms of an injunction. However, in two summary sheets filed by the plaintiffs,4 they expressly designated this action as a rule 80B appeal from the decision of a governmental body. Any pleading, including a complaint, must be accompanied by a "properly completed" summary sheet. M.R.Civ.P. 5(h). This requirement is not meaningless, particularly in the circumstances of his case, because a pleading party's characterization of a claim determines the process that the claim will follow through the court system. When a plaintiff treats a claim as a rule 80B appeal rather than as an independent civil cause of action, then the defendant is not required to file a responsive pleading, the parties are required to file a record of the administrative proceeding and the court

establishes a briefing schedule. None of these procedural aspects of an

3The defendants contend that the complaint was not filed in a timely way. Such a procedural defect would be jurisdictional. See Davric Maine Corp. v. Bangor

Historic Track, Inc., 2000 ME 102, | 11, 751 A.2d 1024, 1029-30. This issue, however, is different than the one discussed in the text.

4A second summary sheet was required because the first was on an outdated form. appeal apply to an independent claim.

Here, in response to the court's questions at the February 20 hearing, the plaintiffs requested the court to treat their complaint as an amalgamation of a rule 80B appeal and an independent claim for injunctive relief. Because the plaintiffs themselves designated their claim as appellate in nature and because a shift in the nature of the action would create fundamental changes in the procedural course in this case, at this time the court declines to treat the complaint as anything other than the type of case that the plaintiffs themselves chose to file, namely, a rule 80B appeal.> The resulting question is whether rule 80B is an available procedural mechanism for the relief sought here by the plaintiffs.

Rule 80B provides a procedural avenue by which a party can seek review of governmental action when a right of appeal "is provided by statute or is otherwise available by law... ." MRCiv.P. 80B(a). The rule itself does not create a right of appeal from governmental action. Lyons v. Board of Directors of S.A.D. 43, 503 A.2d 233, 235 (Me. 1986). None of the parties have identified any statute that allows an appeal from a municipality's decision not to include an article on a town warrant when ‘the article is the subject of a petition that satisfies the numerical requirements of 30-A M.R.S.A. § 2522. The court's research revealed no such authority. The next question is therefore whether this type of court action is "otherwise available by law" within the meaning of rule 80B(a).

"An action for an injunction in the nature of mandamus may be

SIf, on the other hand, the case became viewed as one that raised an independent claim, then procedural complications would ensue because, for example, the deadline for a responsive pleading has already passed. These types of important procedural implications must be balanced against the plaintiffs’ verbal request that the case be seen in part as an independent claim.

4 ‘otherwise authorized by law’ if it is the type of action for which the traditional writ would apply." Casco Northern Bank, N.A. v.

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