Pelkey v. State of Maine, Office of the Secretary of State

CourtSuperior Court of Maine
DecidedAugust 21, 2000
DocketKENap-99-59
StatusUnpublished

This text of Pelkey v. State of Maine, Office of the Secretary of State (Pelkey v. State of Maine, Office of the Secretary of State) 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
Pelkey v. State of Maine, Office of the Secretary of State, (Me. Super. Ct. 2000).

Opinion

Ap .

STATE OF MAINE SUPERIOR COURT CIVIL ACTION KENNEBEC, ss. DOCKET NO. AP-99-59, JRA- key - P/aijevee SAMUEL PELKEY, Petitioner

v. DECISION AND ORDER

STATE OF MAINE, OFFICE OF THE SECRETARY OF STATE,

Respondent

This matter is before the court on the petitioner’s appeal of the Secretary of State’s refusal to reconsider its decision suspending the petitioner’s motor vehicle license. The respondent has moved to dismiss the appeal, but the parties have agreed that the court may address the motion to dismiss and the merits of the appeal at the same time so that it may enter a final disposition of this case.

By way of history, the record shows that the petitioner was convicted of Operating Under the Influence, 29-A M.R.S.A. § 2411, in the Lincoln District Court on April 7, 1998, at which event his driver’s license was suspended for 90 days. The Secretary of State, however, imposed on the petitioner a concurrent license suspension of 18 months because.he had been previously adjudicated or convicted of Operating Under the Influence or had previously failed to submit to a test to measure blood-alcohol level. See 29-A M.R.S.A. § 2451(3)(B) (1996). The respondent notified the petitioner of this suspension via a notice that was “mailed no later than

4/14/98.” The 18-month suspension was scheduled to terminate in October of 1999. Petitioner, with different counsel, filed a request for a hearing with the respondent on August 25, 1998. The respondent denied this request as untimely pursuant to 29-A M.R.S.A. § 2483 which requires that a request for a hearing to review a license suspension “determination” must be made “within 10 days from the effective date of the suspension.” Id. The statute also provides that the 10-day period may be waived if the respondent finds that the driver “was unable to make a timely request due to lack of actual notice of the suspension...” Id. at § 2483(3).

The petitioner has argued that he was unable to make a timely request because the notice he received did not comply with the requirements of 29-A M.R.S.A. § 2482(2)(C), (D), (E), and (F) in that it did not advise him of his right to request a hearing, the procedure for such a request, and the date by which a request for a hearing must be made. He has also argued that the 18-month suspension was erroneously imposed because it was based on an adjudication in 1990 which was, in fact, an acquittal because it had been determined that there was no probable cause to stop him and the evidence against him had been excluded. That being so, he argues, the respondent is barred from using any information against him just as the prosecutor had been, and cannot use that information to suspend his license.

Because of these alleged errors, the petitioner, on several occasions, asked the respondent to reconsider its decision suspending his license, but to no avail. He has turned to this court for relief and filed his petition for review of final agency action

on July 14, 1999. The record was filed on July 28, 1999. No action occurred in the case until April 21, 2000, when the court received a letter from respondent’s counsel calling the court’s attention to the inaction in the case and inquiring if the appeal had been dismissed or withdrawn. The petitioner responded that the appeal had not been withdrawn and that he was awaiting action by the court. On April 24, 2000, the court issued a briefing schedule. By the time this correspondence was exchanged, and the scheduling order issued, the petitioner’s driver’s license had been restored.

In its motion to dismiss, the respondent cites three essential reasons why the appeal cannot succeed and should be dismissed: the April 14, 1998 suspension was not defective, the 1990 suspension cannot be collaterally attacked in this appeal, and the appeal is moot because the petitioner has completed his suspension period, has met the conditions for license restoration, and has been issued a valid driver's license.

Because this final point has merit, the court concurs with the respondent that the appeal is in order to be dismissed as moot.

“The concept of mootness is based on the principle that ‘courts should decline to decide issues which by virtue of valid and recognizable supervening circumstances have lost their controversial vitality.’” State v. Jordan, 1998 ME 174, q 10, 716 A.2d 1004, 1006 (quoting State v. Gleason, 404 A.2d 573, 578 (Me. 1979)). “The test for mootness is whether there remain sufficient practical effects flowing from the resolution of the litigation to justify the application of limited judicial

resources.” Maine Civil Liberties Union v. City of South Portland, 1999 ME 121, { 8, 734 A.2d 191, 194 (quoting Nugent v. Town of Camden, 1998 ME 99, J 6, 710 A.2d 245, 247).

The Law Court has recognized three exceptions to the mootness principle:

First, the court will determine whether sufficient collateral

consequences will result from determination of the questions

presented so as to justify relief. Second, while technically moot in the immediate context, questions of great public interest may nevertheless

be addressed for the future guidance of the bar and the public. Third,

issues which may be repeatedly presented to the trial court, yet escape

review at the appellate level because of their fleeting or determinate

nature may appropriately be decided. Lewis v. State, 2000 ME 44, { 4, 747 A.2d 1191, 1192 (quoting Gleason, id., 404 A.2d at 578).

The petitioner, in his reply to the motion to dismiss, relies on the last of these exceptions to the mootness principle, namely that the issue which he presented at the administrative level of the inadequate notice of his right to a hearing, escapes review at the appellate level although it is capable of reoccurrence to others similarly situated. Under this exception “[u]nless the questions that have become moot occur in a context where there is a ‘reasonable likelihood that the same issues will imminently and repeatedly recur in future similar contexts with serious impact upon important generalized public interests,’ the determination of those questions should be avoided.” Maine Civil. Liberties Union v. City of South Portland, 1999 ME 121, J 10, 734 A.2d 191, 195 (quoting Campaign for Sensible Transp. v. Maine Turnpike Auth., 658 A.2d 213, 215-16 (Me. 1995)).

The statute which prescribed the contents of the notice of suspension, 29-A

M.R.S.A. § 2482, has been amended since the petitioner received his allegedly

4 defective notice. By virtue of the Public Laws of 1997, c. 776, § 50 (eff. July 9, 1998), subparagraphs D and E of section 2482 were repealed so that the Secretary of State is no longer required to advise a suspended operator as to the procedure for requesting a hearing and the date by which the request for a hearing must be made. That being so, the central basis on which the petitioner claims he was deprived of a hearing, namely a defective notice of his right to a hearing and how and when to request one, will not reoccur, absent further legislative action. Accordingly, this court cannot find that this issue has any likelihood of repeating itself, so that it must be concluded that the cited exception to the mootness doctrine is inapplicable here.

The same conclusion would have to be made as to the effect of the exclusion of evidence at a criminal trial as to an administrative determination of license suspension. The Law Court has ruled that the exclusionary rule does not apply to administrative license suspension proceedings. Powell v.

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Related

Maine Civil Liberties Union v. City of South Portland
1999 ME 121 (Supreme Judicial Court of Maine, 1999)
In Re Nathaniel B.
1998 ME 99 (Supreme Judicial Court of Maine, 1998)
Nugent v. Town of Camden
1998 ME 92 (Supreme Judicial Court of Maine, 1998)
Lewis v. State
2000 ME 44 (Supreme Judicial Court of Maine, 2000)
State v. Jordan
1998 ME 174 (Supreme Judicial Court of Maine, 1998)
Campaign for Sensible Transportation v. Maine Turnpike Authority
658 A.2d 213 (Supreme Judicial Court of Maine, 1995)
State v. Gleason
404 A.2d 573 (Supreme Judicial Court of Maine, 1979)
Powell v. Secretary of State
614 A.2d 1303 (Supreme Judicial Court of Maine, 1992)
State v. O'Neill.
473 A.2d 415 (Supreme Judicial Court of Maine, 1984)

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