Roy v. Inhabitants of City of Augusta

387 A.2d 237, 100 A.L.R. 3d 245, 1978 Me. LEXIS 907
CourtSupreme Judicial Court of Maine
DecidedJune 2, 1978
StatusPublished
Cited by5 cases

This text of 387 A.2d 237 (Roy v. Inhabitants of City of Augusta) 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
Roy v. Inhabitants of City of Augusta, 387 A.2d 237, 100 A.L.R. 3d 245, 1978 Me. LEXIS 907 (Me. 1978).

Opinion

WERNICK, Justice.

In September 1976 the municipal officers of the City of Augusta granted plaintiff Donald Roy a license to operate a billiard room on Cony Street in Augusta until May 1,1977. Plaintiff applied for the prescribed annual renewal of his license, which the municipal officers refused on April 13,1977. Seeking judicial review, plaintiff brought an action in the Superior Court (Kennebec County) against the Inhabitants of the City of Augusta and the City’s municipal officers. Plaintiff asked the Court to direct *238 the municipal officers to renew his license. 1 On November 16, 1977 the Superior Court sustained the decision of the Augusta municipal officers. Plaintiff has appealed from this judgment, and we sustain the appeal.

Under 8 M.R.S.A. § 1 a person who keeps a bowling alley, shooting gallery or billiard room without a license “forfeits $10 for each day that such alley, gallery or room is so kept.” As part of the same statutory scheme, 8 M.R.S.A § 2 delegates the licensing responsibility to the various municipalities under guidelines, relevant here, as follows:

“Municipal officers of towns may license suitable persons to keep bowling alleys, shooting galleries, pool, bagatelle and billiard rooms therein, in any place where it will not disturb the peace and quiet of a family, for which the person licensed shall pay $10 to such town. Such licenses expire on the first day of May after they are granted, unless sooner revoked.” 2

As purportedly in accord with this enabling statute, the Augusta City Council enacted an Ordinance providing:

“Sec. 3-7. Bowling alleys, shooting galleries, pool, billiard rooms — license required, prerequisites.
“(a) No person shall operate a bowling alley, shooting gallery, pool or billiard room without obtaining a license from the municipal officers.
“(b) Such license shall be granted only if the location is in such a place that it will not disturb the peace and quiet of a family, and such license shall be renewed on or before the first day of May annually.” (Code 1957, Ch. 15, § 8)

In the instant situation the municipal officers of Augusta refused to renew plaintiff’s license because of evidence that large numbers of young people assembled on the public sidewalk, or street, outside of plaintiff’s billiard room, and such assemblages constituted a disturbance to the peace and quiet of families in the area. There was no evidence before the municipal officers that the activities going on inside the billiard room disturbed the peace and quiet of any family; indeed, the evidence was plainly to the contrary.

The statutes here involved date back to the middle of the 19th century 3 when bowling (and playing billiards) suffered the moral stigma described in State v. Haines, 30 Me. 65, 75, 76 (1849):

“The ‘hurt’ or injury to the community, which has occasioned bowling alleys kept for gain and common use to be regarded as common nuisances, arises from their tendency to withdraw the young and inconsiderate from any useful employment of their time, and to subject them to various temptations. . . . Clerks, apprentices and others are induced, not only to appropriate to them hours, which should be employed to increase their knowledge and reform their hearts, but too often to violate higher moral duties to obtain means to pay for the indulgence. Other bad habits are in such places often introduced or confirmed. The moral sense, the correct principles, the temperate, regular and industrious habits, which are the basis of a prosperous and happy community, are frequently impaired or destroyed. Bowling alleys without doubt may be resorted to by many persons without such injurious results. The inquiry is not what may be done at such places without injury to persons of fixed habits and principles, but what has been in the experience of man, their general tendency and result. The law notices the usual effect, the ordinary result of a pursuit or course of conduct, and by that *239 decides upon its character. It need not be the necessary and inevitable result of a bowling alley kept for gain and common use, that it is thus injurious to the community, to make it a common nuisance.”

Because in the mid-1800’s, as State v. Haines decided, a bowling alley was deemed per se a common nuisance, the keeping of a bowling alley was per se unlawful; the activity itself was evil, as exerting “immoral” influences.

In 1855, six years after the decision in Haines, the Legislature ameliorated the common nuisance approach of Haines. Acknowledging that if properly regulated a bowling alley can be “suitably” kept, the Legislature by P.L.1855, chap. 167 authorized municipalities to license “suitable” persons to keep bowling alleys and further provided that any bowling alleys kept without a license would be unlawful. To govern the exercise of the licensing power, as delegated to municipalities, the Legislature prescribed that no license shall be issued for the keeping of a bowling alley if “. . . it will disturb the peace and quiet of any neighborhood or family.” P.L.1855, chap. 167 § 6. In addition, the Legislature in the same statute prohibited the use of the premises where a bowling alley is kept during certain hours, or by a minor without the consent of a parent or guardian, or for gaming or the drinking of intoxicating liquors. P.L.1855, chap. 167, §§ 3, 4.

Also in 1855 the Legislature, by a separate statute, undertook to regulate the activity transpiring in billiard rooms by establishing particular hours for the use of the premises and prohibiting the use of the premises by minors without the consent of a parent or guardian. P.L.1855, chap. 141, § 1. However, it was not until 1857 that the keeping of billiard rooms was made subject to licensing provisions similar to those previously established for the keeping of bowling alleys. R.S.1857, chap. 29, §§ 3, 4. Municipal officers were then given responsibility for the licensing of any “suitable” person to keep a billiard room “. . . in any place where it will not disturb the peace and quiet of a family.” R.S.1857, chap. 29, § 4.

The mores of the mid-1800’s may have warranted upholding the constitutionality of legislation specially regulating, by licensing, the keeping of bowling alleys and billiard rooms under a standard so broad that incidents occurring on the public sidewalks or streets outside the confines of a bowling alley or billiard room could constitute a disturbance justifying denial of a license— on the rationale that the per se “immorality” of such activities made such external disturbances highly expectable. In modern times, however, bowling and playing billiards weigh much differently in our scale of values; they are acceptable, and indeed respectable, as beneficial recreational pursuits.

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Bluebook (online)
387 A.2d 237, 100 A.L.R. 3d 245, 1978 Me. LEXIS 907, Counsel Stack Legal Research, https://law.counselstack.com/opinion/roy-v-inhabitants-of-city-of-augusta-me-1978.