Patrick Gordon v. Maine Commission on Public Defense Services

2024 ME 59
CourtSupreme Judicial Court of Maine
DecidedAugust 8, 2024
DocketKen-23-393
StatusPublished

This text of 2024 ME 59 (Patrick Gordon v. Maine Commission on Public Defense Services) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patrick Gordon v. Maine Commission on Public Defense Services, 2024 ME 59 (Me. 2024).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2024 ME 59 Docket: Ken-23-393 Argued: May 7, 2024 Decided: August 8, 2024

Panel: STANFILL, C.J., and MEAD, HORTON, CONNORS, and LAWRENCE, JJ.

PATRICK GORDON

v.

MAINE COMMISSION ON PUBLIC DEFENSE SERVICES

MEAD, J.

[¶1] Patrick Gordon appeals from the judgment of the Superior Court

(Kennebec County, Lipez, J.), entered pursuant to M.R. Civ. P. 80C, affirming a

final decision of the Maine Commission on Public Defense Services,1 that

suspended him from Commission rosters and thereby rendered him ineligible

for assignment to represent indigent criminal defendants. See M.R.U.

Crim. P. 44(a)(1)-(2). Upon review of the Commission’s decision, we affirm.

I. BACKGROUND

[¶2] The Commission “is an independent commission whose purpose is

1 During the underlying proceedings and when this appeal was filed, the Maine Commission on Public Defense Services was called the Maine Commission on Indigent Legal Services, but the Commission’s title was changed on March 21, 2024. See P.L. 2023, ch. 558, § 2 (emergency, effective Mar. 21, 2024). 2

to provide efficient, high-quality representation to indigent criminal

defendants, juvenile defendants and children and parents in child protective

cases, consistent with federal and state constitutional and statutory

obligations.” 4 M.R.S. § 1801 (2024). Rule 44 of the Maine Rules of Unified

Criminal Procedure requires the court to appoint attorneys listed on rosters

maintained by the Commission to serve as counsel for indigent criminal

defendants who are at risk of incarceration or certain collateral consequences.

M.R.U. Crim. P. 44(a).

[¶3] At the time of the proceedings here, attorneys who wished to be

listed on a Commission roster were required to register with the Commission.

See 94-649 C.M.R. ch. 2, § 3 (effective Sept. 17, 2015).2 To be compensated by

the Commission for work on a case, a Commission-rostered assigned attorney

must submit a voucher reflecting the work performed for the client in that case.

See 94-649 C.M.R. ch. 301, § 6 (effective Feb. 6, 2024).

[¶4] Gordon first registered with the Commission in or about 2010 and

reregistered annually with the Commission in the following years.

There has been an amendment to 94-649 C.M.R. ch. 2 since the underlying proceedings in this 2

appeal, see 94-649 C.M.R. ch. 2 (effective May 14, 2024), but the amendment does not affect this appeal. 3

[¶5] In January of 2021, the Commission received information from an

attorney who had been assigned as post-conviction review (PCR) counsel for a

client whom Gordon had represented at trial as assigned counsel compensated

by the Commission. The information prompted the Commission to begin an

investigation into Gordon’s billing and statements related to his representation

of the client. Specifically, the information suggested that Gordon had submitted

a voucher for representing the client in a jury trial when the trial was in fact a

bench trial and that certain time entries in the vouchers were for work done

not by Gordon but by a paralegal or another attorney at Gordon’s firm.

Additionally, there appeared to be a discrepancy as to whether it had actually

been Gordon who had visited his client at all of the times the billing records

listed. The Commission believed that the information shared by the PCR

counsel raised questions concerning Gordon’s performance representing

indigent clients and apparent inaccuracies in Gordon’s billing for work done in

the case.

[¶6] During the Commission’s investigation of Gordon, the following

events transpired:

 On February 12, 2021, Justin Andrus, the Commission’s Interim Executive Director, sent Gordon a letter informing him of the investigation and requesting the following documents and information: 4

o Request 1: Gordon’s client file from his representation of the client;

o Request 2: clarification as to any potential billing discrepancies in relation to the client’s case;

o Request 3: clarification as to the discrepancy in Gordon’s payment voucher that represented a bench trial to be a jury trial; and

o Request 4: a list of the dates that Gordon met with the client.

 On February 19, 2021, Gordon informed the Commission of his receipt of the letter and on March 10, 2021, requested further time to respond to the requests.

 On March 15, 2021, Gordon emailed a letter to Andrus responding to the requests. Initially Gordon raised questions about the investigation process and whether Andrus, as interim executive director, had the authority to conduct the investigation.3 Referencing the Commission’s four requests, Gordon responded as follows:

o As to Request 1: he thought that his response to Request 1 needed to be limited due to his concerns about violating attorney-client privilege, he believed that the Commission had the billing statement in the case, and he would provide no further documents;

o As to Request 2: upon reviewing the billing records, he noted one entry for attorney work that appeared to have been billed by an office manager, but that it had only been “entered” by the manager, and not improperly billed;

3 The Commission’s rules in force at that time referred to the “Executive Director” in the section

that required a Commission rostered attorney to “comply with any Commission investigation of complaints . . . or other information that, in the view of the Executive Director, concerns the question of whether the attorney is fit to remain on the roster.” 94-649 C.M.R. ch. 2, § 2(2) (effective Sept. 17, 2015) (emphasis added). 5

o As to Request 3: the trial in question had indeed been a bench trial, but Gordon was not aware of the voucher that misrepresented the bench trial as a jury trial; and

o As to Request 4: he was “not sure exactly of all the dates [he] met with [the client],” “rarely entered all of [his] billing time,” and provided a non-exhaustive list of times he “believe[d he] met with [the client],” acknowledging that in some instances he did not “know the dates” of the meetings.

Gordon further stated that if the Commission required more information, he would be willing to supply it and requested that the Commission provide more specific details about what was sought by the requests.

 On April 30, 2021, by email and letter, Andrus responded to Gordon’s letter, asserting the appropriateness of the process and his authority to conduct the investigation. The letter further indicated that Andrus believed that Gordon’s provided answers were “partial answers” and clarified that Request 1 sought Gordon’s client file from the case. The letter made three additional requests for information as to billing and files pertaining to Gordon’s representation of the client, with a deadline of May 10, 2021, specifically requesting the following information:

o Request 5: a confirmation that the time entries in the billing vouchers submitted to the Commission were performed by the individuals listed for the entries;

o Request 6: a clarification as to why Gordon had been “unable to provide . . . copies of correspondence sent to [his client]” when they were requested in conjunction with the PCR case of the client and Gordon’s file retention policy; and

o Request 7: an explanation as to why Gordon had not complied with multiple court orders that he provide copies of client trial files to the PCR attorney.

 On May 10, 2021, Gordon emailed Andrus requesting an extension of time and indicating that on May 7, 2021, he had asked the Maine Board of 6

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