Saunders v. Town of Standish

CourtSuperior Court of Maine
DecidedJanuary 26, 2006
DocketCUMap-05-054
StatusUnpublished

This text of Saunders v. Town of Standish (Saunders v. Town of Standish) 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
Saunders v. Town of Standish, (Me. Super. Ct. 2006).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, SS DOCKET NOS. AP-05-054

HENRY W. SAUNDERS, MARJORIE H. SAUNDERS, LESLIE S. SAUNDERS and KENNETH W. SAUNDERS

Plaintiffs CONSOLIDATED ORDER vs. ON DEFENDANTS' MOTIONS TO DISMISS 80B APPEALS TOWN OF STANDISH

Defendant

SYLVIA L. THOMPSON, TRUSTEE

Plaintiff

VS.

TOWN OF STANDISH

Before the court are respondent Town of Standish's ("Town") motions to

dismiss plaintiffs Henry, Marjorie, Leslie and Kenneth Saunders' and plaintiff

Sylvia Thompson, Trustee's (collectively, "Plaintiffs") 80B appeals for lack of

jurisdiction. On December 21, 2005, the court granted the Town's unopposed

motion to consolidate these appeals for the limited purpose of deciding these

motions.

BACKGROUND

Plaintiffs challenge their April 1, 2004 tax assessment on residential

properties located on Sebago Lake in Standish. Following denial of their tax 1 abatement applications, Plaintiffs appealed to the Board of Assessment Review,

("BAR) which conducted hearings on July 13, 2005. At the conclusion of the

hearings, the BAR voted to grant a partial tax abatement, reducing the

assessment on the Saunders property from $1,273,200 to $1,100,000 and on the

property held in trust by Thompson from $1,348,700 to $1,140,000. Plaintiffs

were present at these hearings and received actual notice of the BAR decisions on

July 13, 2005. The BAR issued written decisions on both appeals dated July 14,

2005, and mailed them to Plaintiffs. Plaintiffs filed appeals of the BAR decisions

on August 16,2005.

DISCUSSION

The Town claims that, because Plaintiffs filed their 80B appeals 34 days

after the July 13 hearings, this court lacks jurisdiction to hear their appeal. It is

well established that time limits to appeal are jurisdictional. See e.g. Persson v.

Dept. of Human Services, 2001 ME 124, ¶ 9, 775 A.2d 363, 365. 36 M.R.S.A. 5 843,

which governs appeals from property tax assessments, states:

[Elither party may appeal from the decision of the board of assessment review directly to the Superior Court, in accordance with Rule 80B of the Maine Rules of Civil Procedure. If the board of assessment review fails to give written notice of their decision within 60 days of the date the application is filed, unless the applicant agrees in writing to further delay, the application shall be deemed denied and the applicant may appeal to Superior Court as if there had been a written denial.

M.R.Civ.P. 80B(b) states, "the time withn which review may be sought shall be

as provided by statute, except that if no time limit is specified by statute, the

complaint shall be filed within 30 days after notice of any action or refusal to act

of w h c h review is sought." The Town points out that Plaintiffs had actual notice

of the Town's action on July 13, 2005, and asserts that, accordingly, the 30-day 2 appeals period began to run from that date. Loolung solely at the language of

Rule 80B, the appeals period would seem to commence on July 13, as the general

meaning of "notice" includes actual notice. See Rowe v. Hayden, 149 Me. 266,271

(Me. 1953); see also Garner, Bryan A., ed. Black's Law Dictionary, 1087 (7thed., 1999)

(stating, "A person has notice of a fact or condition if that person (1)has actual

knowledge of it...").

Plaintiffs maintain, however, that 5 843, from whch Rule 80B derives its

authority for sethng the appeals period, indicates that "notice" in the context of a

BAR decision is to be "written." They then point out that they received written

notice through the mail, dated July 14, 2005. They conclude that, pursuant to

M.R.Civ.P. 6(c), they have 33 days from the date of the written notice to initiate

their appeal.

M.R.Civ.P.6(c) states:

Whenever a party has the right or is required to do some act or take some proceedings withn a prescribed period after the service of a notice or other paper upon the party and the notice or paper is served upon the party by mail, 3 days shall be added to the prescribed period.

Plaintiffs' argument is compelling in light of the specific language of § 843. The

Law Court has stated that, in deciding when an appeals period begins to run, the

court must first take a close look at the language of the governing statute. See

Vachon v. Town of Kennebunk, 499 A.2d 140, 141 (Me. 1985); see also Woodward v.

Town of Newfield, 634 A.2d 1315, 1317 (Me. 1993). Vachon and Woodward

construed statutes that required any appeal to be taken "within 30 days after the

decision is rendered." See id. Vachon noted that the critical word in the

governing statute was "rendered" and stated, "a decision is 'rendered' when the

tribunal makes, gives, or delivers it." See Vachon, 499 A.2d at 141. It concluded, 3 therefore, that the appeals period began to run as to the date the zoning board of

appeals had heard and voted on the plaintiff's appeal. Id. In support of this

interpretation, the court noted that, if the legislature had intended to delay the

start of the appeal period until the appellant had received notice of the zoning

board's decision, it could have stated, as it has in statutes governing appeals

from state administrative agencies, that the appealing party would have to

appeal "within 30 days after receipt of notice." See id.

The court also looked to the circumstances of a zoning appeal to explain

why the appeals period should run from the date of the hearing and oral

decision as opposed to the date of the written decision. In zoning cases, any

party to the proceeding, including abutters, may appeal the zoning board's

decision, however, only the petitioner and certain municipal agencies must be

given "notice" of the decision. See id. The court concluded from this that, "the

limitation on the notice required . .. negates by clear implication any suggestion

that receipt of notice of a zoning board's decision is a prerequisite for the start of

the appeal period." Id.

Both the statutory language and the circumstances of this appeal differ

from Vachon. Here, "notice" is the crucial statutory language, not the time at

which the decision is rendered. Although § 843 does not clearly state that an

appeal must be taken "within 30 days of receipt of notice," it does provide that,

in the absence of "written notice of their decision," the application will be

deemed denied 60 days after the application has been filed. Additionally, in the

context of a tax assessment appeal, the only parties with an interest in the action

are the applicant and the municipality. There are no third party appeal rights,

and there is, consequently, no need for the date of the public hearing and vote to 4 serve as the date from which any interested party might appeal. Although

ordinarily, the meaning of "notice" under Rule 8ClB would include actual notice,

it is more consistent with the language of § 843, as well as the circumstances of a

tax abatement appeal, to here interpret the meaning of "notice" as "written

notice."

Written notice of the BAR's decision was sent via mail to Plaintiffs on July

14, 2005. Under 3 843, Plaintiffs have the right to appeal the BAR's decision after

written notice of the appeal.

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Related

Twigg v. Town of Kennebunk
662 A.2d 914 (Supreme Judicial Court of Maine, 1995)
Persson v. Department of Human Services
2001 ME 124 (Supreme Judicial Court of Maine, 2001)
Central Maine Power Co. v. Town of Moscow
649 A.2d 320 (Supreme Judicial Court of Maine, 1994)
Rowe v. Hayden
101 A.2d 190 (Supreme Judicial Court of Maine, 1953)
Ryan v. Town of Camden
582 A.2d 973 (Supreme Judicial Court of Maine, 1990)
McCullough v. Town of Sanford
687 A.2d 629 (Supreme Judicial Court of Maine, 1996)
Shawmut Inn v. Inhabitants of Kennebunkport
428 A.2d 384 (Supreme Judicial Court of Maine, 1981)
Vachon v. Town of Kennebunk
499 A.2d 140 (Supreme Judicial Court of Maine, 1985)
Yusem v. Town of Raymond
2001 ME 61 (Supreme Judicial Court of Maine, 2001)
York v. Town of Ogunquit
2001 ME 53 (Supreme Judicial Court of Maine, 2001)
Woodward v. Town of Newfield
634 A.2d 1315 (Supreme Judicial Court of Maine, 1993)
Ram's Head Partners, LLC v. Town of Cape Elizabeth
2003 ME 131 (Supreme Judicial Court of Maine, 2003)

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