State of Maine v. Chittim

CourtSuperior Court of Maine
DecidedDecember 5, 2000
DocketYORap-00-046
StatusUnpublished

This text of State of Maine v. Chittim (State of Maine v. Chittim) 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
State of Maine v. Chittim, (Me. Super. Ct. 2000).

Opinion

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STATE OF MAINE SUPERIOR COURT

CIVIL ACTION

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STATE OF MAINE,

Plaintiff / Appellee

v. ORDER

DAVID B. CHITTIM, Defendant/ Appellant

This is an appeal from a District Court adjudication that Mr. Chittim committed a traffic infraction. For reasons stated below, the appeal is Denied.

FACTUAL BACKGROUND

On December 26, 1999, David Chittim’s son was stopped for speeding while operating a vehicle registered to Chittim’s wife. Chittim was a passenger in the car. The police officer observed that a self-adhesive sticker with the message “Taxationland” was placed upon rear license plate. The police officer then inspected the front license plate and discovered a similar sticker that read, “The Crawdad State.” Chittim admitted to affixing both these stickers and was cited for violating 29-A M.LR.S.A. § 2104(4).

A hearing was held before Judge Janelle on March 1, 2000 and a written decision was issued on March 8th, finding that Chittim had violated § 2104(4). A sentencing hearing was subsequently scheduled for April 10th. Chittim’s Notice of Appeal was filed on April 7th. Chittim also filed a “Motion for Stay of Execution.”

At the sentencing hearing on April 10th, neither Chittim nor his counsel appeared before the court. The Motion was denied and a fine of $20 was imposed.! Chittim paid the fine in full on May 8th. DISCUSSION

(1) By paying the fine after the decision was rendered, did Chittim terminate his

right to appeal?

The State argues that by paying the fine after the decision was rendered, Chittim effectively terminated the action. Three of the cases cited by the state to support this proposition involve payments of fines subsequent to a criminal

conviction. State v. Haskell, 492 A.2d 1265 (Me. 1985); State v. Lewis, 406 A.2d 886

(Me. 1979); State v. Madden, 357 A.2d 516 (Me. 1976). In Haskell, Lewis, and

Madden, the discussion largely revolved around M.R. Crim. P. 38 and whether the payment made was a deposit of the fine pending appeal, or a payment of the fine.

The State also cites State v. Osborne, 143 Me 10, 54 A.2d 526 (1947). However, in

Osborne, which is also a criminal case, the Court held that the defendant could not plead guilty, pay his fine, and subsequently file a motion to withdraw his guilty plea.

Chittim argues that he was merely complying with the guidance provided by the Maine Judicial Branch Violations Bureau.” Paragraph four states:

4. Fine Deposit. You must also submit a check or money order for the amount of the fine that was assessed against you, including any surcharge that has been imposed. This check or money order must also be payable to the Violations Bureau. If you win your

appeal, you will get this money back. If you lose your appeal, this sum will pay your fine.

1 29-A M.R.S.A. § 103 states that the exclusive penalty for a traffic infraction is a fine of not less than $25 nor more than $500, unless specifically authorized.

2 See attachment to Appellant’s Reply and Opposition to State’s Motion to Dismiss Appeal.

2 Chittim correctly notes that the above rule makes the payment of his fine pending appeal mandatory. M. R. Crim. P. 38 is inapplicable and cannot be analogized to the present case. A traffic infraction is not a crime. 29-A M.R.S.A. § 103. M.R. Civ. P. 80F(j), governing the appeal of traffic infractions states that “a party entitled to appeal may do so as in other civil actions.” M.R. Civ. P. 62(e) states “the taking of an appeal from a judgment shall operate as a stay of execution upon the judgment during the pendency of the appeal, and no supersedeas bond or other security shall be required as a condition of such stay.” M.R.Crim.P. 38, in contrast, requires that the portion of a sentence involving money “shall be stayed by the court upon request of the defendant if an appeal is taken” and, according to the cases cited by the State, the fine must be designated as payment of the fine, or a deposit of the fine pending appeal.

(2) Because the stickers were attached to the license plate prior to the enactment of

29-A M.R.S.A, § 2104(4), do Chittim’s actions constitute a traffic infraction?

Chittim next argues that because he “added or attached” the stickers prior to the enactment of 29-A M.R.S.A. § 2104(4), his actions could not constitute a traffic infraction. 29-A M.R.S.A. § 2104(4), which became effective July 1, 1996, states:

Alterations to registration plates. Except when a greater penalty is applicable, a person commits a traffic infraction if that person adds or attaches to a registration plate a decal, symbol, slogan, mark, letter or number not authorized by law or by the Secretary of State.

Chittim quotes various cases for the proposition that statutes are considered to have prospective operation only, unless legislative intent to the contrary is clearly

expressed or necessarily implied. Coates v. Maine Employment Security Comm’‘n,

406'A.2d 94 (Me. 1979); Reggep v. Lunder Shoe Products Co., 241 A.2d 802 (Me. 1968);

Sabasteanski v. Pagurko, 232 A.2d 524 (Me. 1967); Miller v. Fallon, 134 Me 145, 183 A. 416 (1936). .

However, the statute in question is not being applied retroactively. By placing the stickers on the plates and by keeping these stickers on the plates after the statute was enacted, Chittim violated the statute. For the same reason, the State’s action is not time-barred by the six-year statute of limitations. 14 M.R.S.A. § 752.°

3. Can a passenger of a vehicle be cited for violating 29-A M.R.S.A. § 2104(4) when

the vehicle is not registered to the passenger?

It is not disputed that Chittim was the passenger of the vehicle in question and that the vehicle is registered to his wife. It is also not disputed that Chittim himself attached the stickers to the plate.* The wording of the statute clearly provides that the person adding or attaching details to a registration plate commits a traffic infraction. The person who altered the plate, by the plain terms of the

statute, need not be the driver or the registered owner.

4. Is requiring the message “Vacationland” or the red lobster precluded by Wooley

v. Maynard?

In Wooley v. Maynard, 430 U.S. 705 (1977), George and Maxine Maynard,

followers of the Jehovah’s Witnesses faith, were charged for covering up the “Live

3 14 M.RS.A. § 752 states: “[a]ll civil actions shall be commenced within 6 years after the cause of action accrues and not afterwards. . .”

& Chittim apparently affixed the stickers when the plates were assigned to a different vehicle. The plates in question were then subsequently attached to the vehicle stopped.

4. Free or Die” motto on New Hampshire’s license plates. Mr. Maynard testified that he found the slogan “morally, ethically, religiously and politically abhorrent.” Id. at 712. 5 The Court stated that the freedom of thought protected by the First

Amendment includes both the right to speak and the right to refrain from speaking

at all. Id. (citing Board of Education v. Barnette, 319 U.S. 624 (1943)).

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Related

West Virginia State Board of Education v. Barnette
319 U.S. 624 (Supreme Court, 1943)
Wooley v. Maynard
430 U.S. 705 (Supreme Court, 1977)
State v. Haskell
492 A.2d 1265 (Supreme Judicial Court of Maine, 1985)
Sabasteanski v. Pagurko
232 A.2d 524 (Supreme Judicial Court of Maine, 1967)
Reggep v. Lunder Shoe Products Company
241 A.2d 802 (Supreme Judicial Court of Maine, 1968)
State v. Lewis
406 A.2d 886 (Supreme Judicial Court of Maine, 1979)
State v. Madden
357 A.2d 516 (Supreme Judicial Court of Maine, 1976)
Miller v. Fallon
183 A. 416 (Supreme Judicial Court of Maine, 1936)
State v. Osborne
54 A.2d 526 (Supreme Judicial Court of Maine, 1947)

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State of Maine v. Chittim, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-chittim-mesuperct-2000.