Quoddy Tides v. Pleasant Point Passamaquoddy Reservation

CourtSuperior Court of Maine
DecidedDecember 29, 2005
DocketWAScv-05-33
StatusUnpublished

This text of Quoddy Tides v. Pleasant Point Passamaquoddy Reservation (Quoddy Tides v. Pleasant Point Passamaquoddy Reservation) 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
Quoddy Tides v. Pleasant Point Passamaquoddy Reservation, (Me. Super. Ct. 2005).

Opinion

STATE OF MAINE SUPERIOR COURT WASHINGTON, ss. CIVIL, ACTION DOCKET NO. CV-05-33

WINIFRED B. FRENCH CORPOFUTION, d/b/a THE QUODDY TIMES, ET AL

Plaintiff

DECISION AND ORDER

PLEASANT POINT PASSAMAQUODDY RESERVATION^, Defendant

This matter is before the court on the complaint of the plaintiffs The Quoddy

Tides and the Bangor Daily News ("Newspapers") for relief under Maine's

Freedom of Access Act ("FOAA"), 1 M.R.S. $5401 et seq., and for a declaratory

j ~ d g m e n t . ~Also before the court is the Reservation's objection to evidence

submitted by the Newspapers at the November 28,2005 trial in this matter.

1 Following a joint motion of Plaintiffs at trial, the Pleasant Point Passamaquoddy Reservation (the "Reservation") was substituted as Defendant in this action in lieu of the Passamaquoddy Tribe. 30 M.R.S.A. 4 6203(6) establishes the Reservation as part of the Passamaquoddy Tribe but with its own council. Defendant argued at sidebar and later in its post-trial brief that the Reservation should have been joined as an indispensable party before trial, and that the Reservation's interests could be prejudiced by being substituted for the Tribe at such a late date. However, counsel for the Tribe and the Reservation was given the opportunity prior to the presentation of Plaintiffs' evidence to reschedule the trial for a later date, after a formal substitution of parties had been made pursuant to M.R. Civ. P. 19, and chose not to do so. Defendant instead reserved the right to present further evidence after the close of the trial.

Count I of the Complaint is styled a "Freedom of Access Appeal" and seeks an expedited trial de novo under the FOAA based upon the Reservation's denial of the Newspapers' requests to inspect and copy certain records of the Reservation. 1 M.R.S.A. 408 (Supp. 2005). Count I1 seeks a declaration that certain meetings of the Reservation Council are public proceedings under the FOAA to which the On September 9, 2005, the Newspapers filed a two count complaint alleging

that the Reservation violated the FOAA by wrongfully denying the Newspapers7

requests for access to records and documents relating to the Reservation's

negotiations of a lease of its land to Quoddy Bay LLC for the development of a

liquefied natural gas facility ("LNG facility") (Count I), and seeking a declaration

that that all meetings of the Reservation or its Council relating to the LNG facility

are "public proceedings" under the FOAA and must be open to the public (Count

11).

A. RESERVATION'S TO EVIDENCE OBJECTIONS AT HEARING OFFERED

The Reservation participated in the evidentiary hearing in this matter subject

to a continuing objection to the relevancy of the testimony and documents offered

into evidence by the Newspapers. The Newspapers sought to establish .the capacity

in which the Reservation was acting by reference to a similar LNG proposal

brought to the Town of Harpswell, and by evidence of the likely impact such a

facility would have on the public outside the borders of the tribal lands. Because

the evidence was offered pursuant to a mixed fact-law question that both parties

Newspapers and the general public have a right of access. As such, both counts are in the nature of appeals from alleged governmental action. M.R. Civ. P. 80B; see Baker's Table, Inc. v. City of Portland, 2000 ME 7 at 711, n. 6; see also Blethen Me. Newspapers, Inc. v. State, 2005 ME 56, 713-6; Bangor Publishing Co. v. Bucksport, 1995 Me. Super. Lexis 8 0 , 1 4 .

Count I1 also seeks a broader declaration that Council meetings at which "other matters not solely related to internal tribal affairs" must also be open to the public. The court concludes that this broad and non-specific claim for relief seeks an impermissible advisory opinion. agree is central to the court's decision, see Part I1 of this opinion, infia, the court

overrules the Reservation's objection.

B. PAPERFRAMEWORK THEGREATNORTHERN

Both parties agree that Great Northern Paper, Inc. v. Penobscot Nation

provides the framework within which the Newspapers' claims are resolved. See

2001 ME 69, 770 A.2d 574. This decision lays out a four-part test for determining

the applicability of state laws to the tribes that are recognized and governed by the

Maine Implementing Act, 30 M.R.S. $5 6201 et seq. Id. at 7 42. The

Passamaquoddy Tribe is recognized and governed by the Act, and the Reservation,

as a political subdivision of the Tribe, is also governed by it.' 30 M.R.S.A. 5 6202.

Under the first prong of the test, the court must determine to what entities

the statute at issue applies. Id. Great Northern Paper established that the FOAA

in particular applies to "public proceedings," which are defined as "the transactions

of any hnctions affecting any or all citizens of the State by a municipality." Id. at

7 43. Therefore, the FOAA applies to municipalities. Id. at 44. Second, the court must determine whether the Reservation is acting in its

municipal capacity. Id. Under the Maine Implementing Act, when the Reservation

acts as a governmental entity, it is acting in a municipal capacity. Id.

4 On June 24, 1996, the Passamaquoddy Tribe and the Reservation entered into an agreement whereby the Reservation was acknowledged as a political subdivision of the Tribe. The third and fourth prongs of the Great Northern Paper test are contingent

upon the outcome of the second. See id. It is only if the Reservation is acting as a

government that the FOAA may apply. See id. And then, even when acting as a

government, application of .the FOAA is limited to proceedings and records that do

not concern internal tribal matters. See id.;see also 30 M.R.S.A. 6206(1).

C. WASTHERESERVATION ACTING AS A GOVERNMENT?

Depending on the circumstances and the activity, a tribe may act in various

distinct capacities - as a sovereign nation, a person or other entity, a business

corporation, or a municipal government. Great Northern Paper at 7 41. For

example, the Law Court found that the Penobscot Nation was acting as a

government when it requested that the EPA and the Federal government treat it

like a state. Id.at 144.

In the instant case, the nature of Reservation's activities is less definitive.

Over a period of months in 2004, the Reservation negotiated a land lease with a

company that intended to build a LNG facility on the leased land. On August 17,

2004, the Reservation voted to continue negotiations with the developer. On May

19, 2005, they reached agreement on the terns of the lease. The Reservation then

sent the proposed lease to the federal government for approval, and within two

weeks, on June 1, 2005, the United States Secretary of the Interior approved the

lease. However, the federal approval process is not yet concluded. The parties

have stipulated that the developer has no right under the lease to use any portion of

the Reservation's land for the LNG project unless and until it completes and files

an Environmental Impact Statement with the Federal Energy Regulatory

Commission ("FERC"), and obtains permits fiom FERC and any other applicable

federal or state authority for the construction and operation of the LNG project.

From these facts alone, it is not possible to say whether the Reservation was

acting in a governmental as opposed to a business capacity. The Newspapers press

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Related

Akins v. Penobscot Indian
130 F.3d 482 (First Circuit, 1997)
Baker's Table, Inc. v. City of Portland
2000 ME 7 (Supreme Judicial Court of Maine, 2000)
Blethen Maine Newspapers, Inc. v. State
2005 ME 56 (Supreme Judicial Court of Maine, 2005)
Couturier v. Penobscot Indian Nation
544 A.2d 306 (Supreme Judicial Court of Maine, 1988)
Great Northern Paper, Inc. v. Penobscot Nation
2001 ME 68 (Supreme Judicial Court of Maine, 2001)
Stickney v. City of Saco
2001 ME 69 (Supreme Judicial Court of Maine, 2001)
Wilde v. Inhabitants of Town of Madison
72 A.2d 635 (Supreme Judicial Court of Maine, 1950)
Davies v. City of Bath
364 A.2d 1269 (Supreme Judicial Court of Maine, 1976)

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