Smith v. Southern Maine Community College

Superior Court of Maine·Decided May 31, 2005·No. CUMap-03-62·Unpublished

Opinion

:; , L;L "' - It STATE OF MAINE ?!ifi";BERLAND, S$ SUPERIOR COURT :Al"f_

CUMBERLAND, ss LLERKDsGFFJCE CIVIL ACTION DOCKET NO. la1 FEB - b A 9: 3b7E-L C A P - C ' , AP-OY ' -- 7 C /

ROBERT SMITH,

Petitioner

v. DECISION AND ORDER AFTER REMAND SOUTHERN MAINE COMM CONIMUNITY COLLEGE, ET AL., DONALD L. GARBRT-C'Y1 [AW LlBRARv

Respondents MAY 1 5 2007

This matter is before the court, after remand, on petitioner Robert

Smith's ("Petitioner") Rule 80B appeal of his termination from employment

by respondent Southern Maine Community College ("SMCC"). Also before

the court is the motion of each party to strike the other's affidavit submitted

in purported compliance with the court's earlier remand order.

BACKGROUND

Petitioner claimed that he was terminated from his employment in

violation of his freedom of speech and due process rights under the Maine

and Federal Constitutions. When the court first considered the merits of

Petitioner's appeal, his free speech argument was rejected. However, the

court found that Petitioner had established a reasonable expectation of

continued employment that amounted to a protected property interest to

1 which due process protections were applicable. Then, turning to the

question of whether Petitioner had been given the process due him, the court

concluded that the record on that issue was inadequate and the case was

remanded for fbrther findings regarding the process afforded Petitioner. In

ordering the remand, this court determined that, even though it was

Petitioner's burden to produce a record sufficient for judicial review, he

could not do so with respect to the due process issue. Subsequently, each

party submitted an affidavit purportedly directed to the "findings"

requirement of the remand order.

The court now concludes after further review that the case should not

have been remanded. More specifically, it is clear that Petitioner failed to

meet his obligation to produce a record sufficient for judicial review of the

due process issue, and the court's prior determination that Petitioner could

not have done so was erroneous. Petitioner never requested a trial of the

facts on this issue, as he could have done pursuant to M.R. Civ. P. 80B(d),

and the court's remand order was tantamount to asking SMCC to create a

factual record that had not existed at the time of the appeal.'

Although Petitioner did not seek a trial of the facts to introduce evidence regarding the due process issue, he did file a motion to join his 8OB appeal with independent claims for constitutional violations (42 U.S.C. § 1983), defamation, intentional misrepresentation, and breach of contract. The court denied the motion, as untimely, and dismissed those independent claims. As the court noted in its prior decision, when necessary findings are

not implicit in the agency's decision or are not otherwise apparent from the

record, "the party aggrieved by the [I decision should request findings of fact

and conclusions of law before asserting the insufficiency of findings as a

ground for judicial review in an action brought pursuant to M.R. Civ. P.

80B." Id. Petitioner did ask for a written enumeration of the reasons for his

termination and received a reply from SMCC's counsel. See Letter of

Attorney Langhauser at Rec. Tab 92 However, he did not ask for or provide

to the court evidence regarding the sufficiency of either the school's notice

to him or his opportunity to be heard. We only know from the existing

record - counsel's letter -that he had an opportunity to be heard and,

from that, we may reasonably conclude that he had prior notice. Stated

another way, it is reasonably implicit from the record evidence of

Petitioner's opportunity to respond that he had some prior notice of the place

where and the time when the opportunity was to be given.

Based upon the foregoing, the court concludes that it should not have

remanded the case and that the decision of SMCC should be affirmed.

Mr. Langhauser's letter recites that "The College reviewed the events and found that the account provided by the students was not denied by Mr. Smith, who was offered the opportunity to present his side." Id. After remand, SMCC submitted the affidavit of Janet M. Sorter,

Ed.D., Vice President and Dean of Academic Affairs of SMCC, describing

the procedure afforded to Petitioner prior to his termination, and Petitioner

submitted his own affidavit.' Neither affidavit constitutes "findings".'

Even if they did, they do not of themselves establish that Petitioner was

given-or not given-the process due him. They only establish that some

process was accorded Petitioner. He was called into a meeting with the

Dean of Academic Affairs and the Dean of Students, he was informed of the

complaints against him, and he was given an opportunity to respond prior to

being discharged.

Decisions of the United States Supreme Court discussing the process

due to government employees in connection with their employment right

establish, first, that governments have broad powers in the selection and

discharge of their employees and, second, that the scope of any right to

continued employment asserted by a government employee is defined by

existing law, rules and standards securing the employment right. See Arnett

v. Kennedy, 4 16 U.S. 134, 15 1 (1974); Board of Regents v. Roth, 408 U.S.

564, 577 (1972); Slochower v. Board of Higher Education of New York City,

Petitioner's affidavit offers a competing version of the process he was given by SMCC. Petitioner would only properly have been able to present the material in this affidavit in a trial of the facts, which he did not request.

In this connection, the Court grants each party's motion to strike the other's affidavit. 350 U.S. 5 5 1, 559 (1956). The only principle that government employment

rules and legislation must honor in every instance is that someprocess,

including, minimally, an inquiry on the part of the government and a hearing

providing the employee an opportunity to defend himself, must be given.

See Roth, 408 U.S. at 577, Slochower, 350 U.S. at 559. SMCC met this

minimum .constitutional standard with the process it provided Petitioner. See

id. What Petitioner has failed to establish is that this process violated any

applicable law or SMCC7sown rules regarding the termination of its

employees.

SMCC is a part of the Maine Technical College System, governed by

20-A M.R.S.A. $5 12701 et seq. 20-A M.R.S.A. Section 12712(5)

establishes that the presidents of the colleges governed by this statute have

the responsibility to evaluate the performance of the faculty and staff of the

colleges under policies and standards developed by the board of trustees.

This is apparently the only statutory authority in Maine governing SMCC7s

actions with regard to Petitioner. Petitioner has not shown how, if at all, this

or any other statutory authority has been violated by SMCC.

Turning to the impact of any applicable school rules, according to the

SMCC Faculty Resource Handbook, disciplinary action to be taken against

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Smith v. Southern Maine Community College, (Me. Super. Ct. 2005).

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