Stanley v. Hancock County Comm'rs

CourtSuperior Court of Maine
DecidedAugust 6, 2003
DocketHANcv-02-23
StatusUnpublished

This text of Stanley v. Hancock County Comm'rs (Stanley v. Hancock County Comm'rs) 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
Stanley v. Hancock County Comm'rs, (Me. Super. Ct. 2003).

Opinion

STATE OF MAINE SUPERIOR COURT HANCOCK, SS. CIVIL ACTION Docket No. CV-02-23 .

A

se

Ronald Stanley,

Plaintiff

V. Order (Defendant’s Motion for Summary Judgment)

prey Fad

Hancock County Commissioners, Defendants

AUG 1 i 2003

Pending before the court is the defendant’s motion for summary judgment on the complaint, in which the plaintiff alleges that he was wrongfully terminated from employment because, in doing so, the defendants violated his rights under the Whistleblower’s Protection Act (WPA), 26 M.R.S.A. § 831 ef seg., and under the Maine Human Rights Act (MHRA), 5 M.R.S.A. § 4551 et seg. The MHRA claim is not independent but rather is the conduit for the WPA claim. See 5 M.R.S.A. § 4572(1)(A). On their motion, the defendants argue that the record on summary judgment does not generate genuine issues of material fact in support of the WPA and MHRA claims. The defendants also contend that the plaintiff is not entitled to recover damages for emotional distress arising from his termination, because the defendants are immunized from liability for such damages under the Worker’s Compensation Act. The court has reviewed the

parties’ written argument and the other materials they have filed in conjunction with the

motion at bar.!

” As part of their reply to the plaintiff’s opposition to the summary judgment motion, the defendants filed an “additional statement of material facts in support of motion for summary judgment.” The rules do not provide for such a submission, see M.R.Civ.P 56(h), perhaps because the motion opponent (here, the plaintiff) has no opportunity to

respond to it. Thus, the court disregards the plaintiff’s “additional statement of material facts.” Summary judgment is proper only if the record on summary judgment shows that there are no genuine issues of material fact and that the movant is entitled to judgment as a matter of law. See M.R.Civ.P. 56. To survive a motion for a summary judgment, the opposing party must produce evidence that, if produced at trial, would be sufficient to resist a motion for a judgment as a matter of law; "[t]he plaintiff must establish a prima facie case for each element of the cause of action." Rodrigue v. Rodrigue, 1997 ME 99, 78, 694 A.2d 924, 926. "'A fact is material when it has the potential to affect the outcome of the suit."" Prescott v. State Tax Assessor, 1998 ME 250, ] 5, 721 A.2d 169, 172. If the evidence favoring the nonmoving party is “merely colorable, or is not significantly probative, a summary judgment may be granted.” See Green v. Cessna Aircraft Co., 673 A.2d 216, 218 (Me. 1996) (citation and internal punctuation omitted).

The parties argue their positions under the burden-shifting framework adopted from federal law in DiCentes v. Michaud, 1998 ME 227, 719 A.2d 509. Under that formula, a WPA claimant establishes a prima facie case by demonstrating that (1) he engaged in an activity that is protected under the WPA, (2) he suffered an adverse employment action, and (3) there was a causal connection between the protected activity and the adverse employment action. The defendant then bears the burden of producing evidence that the adverse employment action was based on a legitimate, non- discriminatory reason. Finally, the plaintiff bears the burden of persuasion to show that the reason offered by the defendant was pretextual. Id.,] 14,719 A.2d at 514.2 For purposes of this case, an activity protected by the WPA occurs when the claimant- employee, “acting in good faith. . reports orally or in writing to the employer or a public body what the employee has reasonable cause to believe is a violation of a law or [state]

tule....” 26 M.R.S.A, § 833(1)(A). The record may also trigger the provisions of

The court also notes that it would be difficult to characterize the defendants’ 20 page, 191 paragraph statement of material facts as “short, and concise. ...” See M.R.Civ.P. 56(h). Although there are many facts that are material to the motion at bar, the amount of duplication within the defendant’s statement of material fact has made it much longer than necessary,

* Although DiCentes did not get past the burdens associated with the prima facie case, the Law Court has made clear that the remainder of the burden-shiftin g approach rooted in McDonnell Douglas v. Green, 411 U.S. 792 (1973) applies to claims brought under Maine’s WPA. DiCentes, 1998 ME 227, J 14, n.10, 719 A.2d at 514. sections 833(1)(B) and (C), which are based the employee’s good faith reports of conditions or practices that place at risk his or another’s health or safety, or the employee’s good faith refusal to carry out a directive that would expose him or another to a condition that would result in serious bodily injury or death, after a correction of the condition has been sought.* The WPA protections are triggered only if the employee first brings the alleged violation to an employment supervisor, and the employer has a reasonable opportunity to correct the violation. Id., § 833(b).

The core of the plaintiff’s claim is that the defendants subjected him to an adverse employment action (namely, termination) at least in part because he had complained to his supervisor, Perley Urquhart, that neither he (the plaintiff) nor several third parties were authorized or competent to perform certain electrical work at a county facility and because he declined to perform certain tasks that he claims were assigned to him. The defendant argues here that the plaintiff’s WPA claim fails as a matter of law because the evidence is insufficient to support an argument that he engaged in an activity protected under that law and that there is insufficient evidence that the adverse employment action was caused by any such conduct.

When the record is viewed in the light most favorable to the plaintiff, it reveals the following factual contentions.

Until his termination on March 13, 2001, the plaintiff was the maintenance supervisor for Hancock County building facilities. Defendant’s Statement of Material Fact (DSMF) { 56. His supervisor was Perley Urquhart, who was the county’s facilities director. DSMF 455. In that capacity, Urquhart had the responsibility to recommend the termination of any employee who he felt was not performing adequately. DSMF { 59.4

*In light of the reasons for the court’s order on the motion at bar, there is no need to examine whether the present record generates a factual argument that all three of these forms of protected activities are implicated in this case.

* The plaintiff disputed this — and a number of other statements of material fact submitted by the defendant — on the ground that although the proposed statement correctly reflects the contents of the record, “the Judge is free to completely disregard this self-serving statement, as it is not from a disinterested witness.” The plaintiff has invoked this basis, without more, for denying such assertions as, “Bickford stamped that memo on February 23° and forwarded copies to the Commissioners,” see POSMF { 6, and “Stanley did not deny many of the things set forth in Urquhart’s memos,” see POSMF { 99. In May and August 2000, Urquhart wrote two memoranda that were critical of the plaintiffs performance of his work duties. DSMF { 68-71. In those reports, Urquhart found fault with the plaintiff’s level of productivity, his use of time and his hostile attitude toward Urquhart himself. See exhibits A and B attached to DSMF. In October 2000, the plaintiff filed a grievance and requested that the May and August reports be

The proffered basis for this approach is the following passage:

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Related

McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Reeves v. Sanderson Plumbing Products, Inc.
530 U.S. 133 (Supreme Court, 2000)
Prescott v. State Tax Assessor
1998 ME 250 (Supreme Judicial Court of Maine, 1998)
DiCentes v. Michaud
1998 ME 227 (Supreme Judicial Court of Maine, 1998)
Green v. Cessna Aircraft Co.
673 A.2d 216 (Supreme Judicial Court of Maine, 1996)
Rodrigue v. Rodrigue
1997 ME 99 (Supreme Judicial Court of Maine, 1997)
Levine v. R.B.K. Caly Corp.
2001 ME 77 (Supreme Judicial Court of Maine, 2001)

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Stanley v. Hancock County Comm'rs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stanley-v-hancock-county-commrs-mesuperct-2003.