Souther v. Concannon, Comm'r, Dep't of Human Servs.

CourtSuperior Court of Maine
DecidedApril 5, 2002
DocketKENap-01-48
StatusUnpublished

This text of Souther v. Concannon, Comm'r, Dep't of Human Servs. (Souther v. Concannon, Comm'r, Dep't of Human Servs.) 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
Souther v. Concannon, Comm'r, Dep't of Human Servs., (Me. Super. Ct. 2002).

Opinion

STATE OF MAINE SUPERIOR COURT CIVIL ACTION KENNEBEC; ss. DOCKET NO. AP-(1-48 Duhi- KEN- 4 [5 [3002

VICKI D. SOUTHER,

Petitioner V. DECISION AND ORDER KEVIN W. CONCANNON, COMMISSIONER, DONALD L. GARSRECHT DEPARTMENT OF WLIEP ty HUMAN SERVICES, Respondent May 10 2002

This matter is before the court upon petitioner’s petition for review in . accordance with MLR. Civ. P. 80C and 5 M.R.S.A. § 1101 et seq. The petitioner is seeking review of a June 4, 2001 final decision by the Commissioner of the Department of Human Services adopting the findings of fact and recommendations of his hearing officer that “the Department was correct when it decided to annotate the Registry of Certified Nursing Assistants to show that the State Survey Agency substantiated an allegation that Vicki Souther abused a resident of Parkview Nursing and Rehabilitation on August 19, 2000.” The petitioner is a CNA who had been employed at Parkview Nursing and Rehabilitation Services for 12 months prior to her termination on August 29, 2000. As such, she was subject to the Maine Registry of Certified Nursing Assistants under rules governing the functioning of the Maine Registry of Certified Nursing Assistants. Under those rules, among other things, the Registry must include a notation of any specific documented findings by the Department of Human Services of abuse,

neglect or misappropriation of property of a resident, client or patient by a CNA

(section A.2.B). Record, Tab D, p. 4. On August 21, 2000, the Division of Licensing and Certification, Bureau of Medical Services, which maintains the Registry, received a complaint alleging that the petitioner had abused a resident on August 19, 2000. The allegation was that the petitioner had punched a resident on the left arm leaving a bruise. After an investigation by the Health Services Consultant for the Division, the Division notified the petitioner that her listing on the Registry would be annotated to reflect the abuse. The petitioner requested an administrative hearing and the Commissioner issued an Order of Reference, referring the matter to the Office of Administrative Hearings. The hearing officer conducted hearings on three different dates on the specific issue:

Should the Maine Registry of Certified Nursing Assistants be annotated to

show that the State Survey Agency substantiated an allegation that Vicki

Souther abused a resident of Parkview Nursing and Rehabilitation

Services on August 19, 2000?

The hearing officer issued a decision recommending that the action proposed by the Division, the State Survey Agency, be affirmed. He further specifically recommended to the Commissioner that the Maine Registry of Certified Nursing Assistants be annotated to show that the State Survey Agency substantiated an allegation that the petitioner abused a resident of Parkview on August 19, 2000. ‘The Hearing Officer issued a 10-page Fair Hearing Recommendation reciting in detail the case background and issue, the parties appearing, the items introduced into evidence, his findings of fact, his recommended decision, and his reasons for the recommendation.

The Office of Administrative Hearings received the petitioner’s letter of exception of 10 pages, wherein petitioner’s attorney responded to the recommended

decision on behalf of the petitioner. The Commission issued a final decision, adopting

the findings of fact and accepting the recommendation of the hearing officer that the Department was correct when it decided to annotate the Registry. The petitioner timely filed this petition for review. In her petition, she denies all allegations of abuse. Generally, petitioner argues that the Department failed to meet its burden or proof in demonstrating that the petitioner committed abuse. She argues that the Commissioner could not have sustained the findings of fact by the hearing officer because it did not have the benefit of the transcripts of the testimony taken by the hearing officer. Further, the Commissioner could not have reached the specific finding that the petitioner punched a patient “in the left upper arm causing a significant bruise,” because it is contrary to the Hearing Officer’s finding of a blow to the “forearm.” Since she asserts that there is disputed evidence as to the size, shape, and location of the bruise, the Hearing Officer’s findings in that regard are not supported by the evidence. Petitioner also claims that the Commissioner committed an error of law by failing to properly comply with the Department's own regulations concerning CNA’s. Regulation B.1 of the DHS rules defines abuse as: ‘The willful, reckless or negligent infliction of injury, unreasonable confinement, intimidation or cruel punishment with resulting physical harm or pain or mental anguish; sexual abuse or exploitation; or the willful deprivation of essential needs. A Certified Nursing Assistant may commit abuse by willfully, recklessly or negligently inflicting injury by responding to the actions of a resident, if the Certified Nursing Assistant’s response was excessive or unwarranted under the circumstances.. Petitioner argues that the evidence shows that her reaction was provoked and the Hearing Officer failed to balance her reaction against the combativeness of the patient. Such failure of findings does not comply with the regulations’ “under the circumstances” requirement. Petitioner asserts that this is an error of law for which she

seeks a total a reversal of the agency decision rather than a remand for further

hearings. The respondent answers that he is not required to hear or read all the testimony presented. He cites, as does petitioner, Green v. Comm'r Dep’t of Mental Health, 2001 ME 86, J 15, 776 A.2d 612. Seealso N.E. Tel. & Tel. Co. v. Maine PUC, 448 A.2d 272, 279 (Me. 1982). The cite by petitioner regarding the Commissioner familiarizing himself with sufficient evidence relates to the authority of agency commissioners to delegate evidentiary and preliminary matters to subordinate officers. The standard, read in proper context, is “as long as the officer both familiarizes himself with the evidence sufficient to assure himself that all statutory criteria have been satisfied and retains ultimate authority to render the decision, he can properly utilize subordinate officers to

au

gather evidence and make preliminary reports.” Davric Maine Corp. v. Maine Harness Racing Comm'n, 1999 ME 99, J 16, 732 A.2d 289, 295.1

In response to the petitioner’s argument, the court does note that in his findings of fact, the Hearing Officer concludes that: “During this incident Ms. Souther handled Helen roughly while putting her into a chair and then Ms. Souther punched Helen with considerable force in the left upper arm causing a significant bruise.” In his reasons for recommendation, the Hearing Officer discusses the evidence and does make reference to testimony as to client’s forearm. Nevertheless, such dicta does not control the specific findings of fact nor does the inconsistency of the discussion remove the

evidence that was before the Hearing Officer. Notwithstanding the forearm/upper

arm misstatement, the Hearing Officer’s findings were supported by substantial

1 The petitioner also complains that the court should not consider the three transcripts of proceedings as part of the record inasmuch as they were not relied upon by the Commissioner. That request was denied. The transcripts, by necessity, must be a part of the record as the proceedings are, by law, a matter of record. The court can clearly consider, in analyzing the Commissioner’s decision, that the transcripts were not completed and available at the time the Commissioner made his final decision. evidence in the record.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

New England Telephone & Telegraph Co. v. Public Utilities Commission
448 A.2d 272 (Supreme Judicial Court of Maine, 1982)
Seider v. Board of Examiners of Psychologists
2000 ME 206 (Supreme Judicial Court of Maine, 2000)
CWCO, INC. v. Superintendent of Ins.
1997 ME 226 (Supreme Judicial Court of Maine, 1997)
Davric Maine Corp. v. Maine Harness Racing Commission
1999 ME 99 (Supreme Judicial Court of Maine, 1999)
Sprague Electric Co. v. Maine Unemployment Insurance Commission
544 A.2d 728 (Supreme Judicial Court of Maine, 1988)

Cite This Page — Counsel Stack

Bluebook (online)
Souther v. Concannon, Comm'r, Dep't of Human Servs., Counsel Stack Legal Research, https://law.counselstack.com/opinion/souther-v-concannon-commr-dept-of-human-servs-mesuperct-2002.