State of Maine v. Kendrick

CourtSuperior Court of Maine
DecidedJuly 7, 2017
DocketCUMcd-VI-16-00875
StatusUnpublished

This text of State of Maine v. Kendrick (State of Maine v. Kendrick) 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. Kendrick, (Me. Super. Ct. 2017).

Opinion

STATE OF MAINE UNIFIED CRIMINAL DOCKET

Cumberland, ss. \~l'L 1 o 2017

STATE OF MAINE

v. Docket Nos. CUMCD-Vl-16-0875, -0876, -0878

HEIDI KENDRICK MARTHA MURDICK and ELIZABETH STOTHART

Defendants

ORDER ON DEFENDANTS' MOTION TO DISMISS

These three consolidated civil violation cases are before the court for decision on

the Motion to Dismiss filed by the Defendant in each case ["combined Motion to

Dismiss"].

The Defendants are alleged to have violated the Maine statute on unlawful

removal of temporary signs in a public right-of-way, 23 M.R.S. § 1917-B.

Defendants do not dispute that they removed the signs that the State says they

did. The Defendants' combined Motion to Dismiss is based solely on the undisputed

content of the removed signs. Defendants say that the statute they are accused of

violating, 23 M.R.S. § 1917-B, prohibits the removal of signs that meet certain criteria,

and that, because the signs they removed do not meet those criteria, they are entitled as

a matter oflaw to have the charges against them dismissed.

The State responds by saying that Maine law prohibits anyone except the

Commissioner of Transportation (or the Commissioner's designee) from removing signs from a public way; that the legislative history of section 1917-B supports the State's

position, and that the Defendant's interpretation would create an absurd result.

Undisputed Facts

Defendants are accused of removing a number of political signs along the public

right-of-way on Route 1 in Falmouth shortly before midnight October 14, 2016, in

violation of23 M.R.S. § 1917-B.

The parties have stipulated that all of the signs at issue were identical in

appearance and wording to the sign admitted as State's Exhibit A. State's Exhibit A is

a double-sided plastic sign that can be slid onto a steel frame with two legs that can be

inserted into the earth. The two sides of the sign are identical, and contain large and

small type. The large type reads as follows:

At the bottom of the sign, a much smaller line of type in the center of the sign

reads as follows:

POL. ADV. PAID FOR BY MAKING MAINE GREAT AGAIN PAC, JULIE SHEEHAN TREASURER. NOTICE: IT IS A VIOLATION OF STATE LAW (CHAPTERS 392 AND 393, TRANSPORTATION CODE) TO PLACE THIS SIGN IN THE RIGHT-OF-WAY OF A HIGHWAY.

2 At each of the lower corners of the sign admitted as Exhibit A, other small type

identifies the manufacturer of the sign and identifies the sign as being made of recycled

material.

Although the sign admitted as Exhibit A identifies the Making Maine Great

Again PAC as having paid for the sign, it does not state whether that organization

placed the sign in the public right-of-way, and does not contain any address for that

organization. It also does not designate the time period during which the sign would be

maintained within the public right-of-way.

Anarysis

The statute that the Defendants are accused of violating reads as follows:

A person who takes, defaces or disturbs a sign placed within the public right-of-way in accordance with section 1913-A, subsection 1, paragraph L commits a civil violation for which a fine of up to $250 may be adjudged. This section does not apply to a person authorized to remove signs placed within the public right-of-way in accordance with section 1913-A, subsection 1, paragraph L.

23 M.R.S. § 1917-B.

The cross-referenced provision, at section 1913-A(l )(L) reads as follows:

L. Temporary signs placed within the public right-of-way for a maximum of 6 weeks per calendar year. A temporary sign may not be placed within SO feet of another temporary sign bearing the same or substantially the same message. A temporary sign may not exceed 4 feet by 8 feet in size. A sign under this paragraph must be labeled with the name and address of the individual, entity or organization that placed the sign within the public right-of-way and the designated time period the sign will be maintained within the public right-of-way.

Defendants read section 1917-B to prohibit the removal only of signs that fully

comply with section 1913-A(l)(L). They say that because the signs in this case do not

3 contain the name and address of the person or persons who placed the signs and the

designated time period the signs would be kept in the public right-of-way, they do not

comply with section 1913-A(l)(L), and thus are not within the scope of the section

1917-B prohibition against removal oflawful signs.

The State says that section 1917-B has to be read in conjunction with 23 M.R.S.

§ 1917, which covers removal of unlawful signs, both inside and outside the public

right-of-way. Unlawful signs outside the public right-of-way must be removed by the

owner within 30 days of receiving a notice to do so from the Commissioner of

Transportation, and may be removed by the Commissioner if the owner fails to comply.

Id. § 1917(1)-(2). Unlawful signs within the public right-of-way may be removed

summarily by the Commissioner. Id.§ 1917(5). The owner of an unlawful sign may be

required to pay the cost of removal by the Commissioner, as well as a penalty of up to

$100. Id.§§ 1917(2)-(3), 1920.

The State also points to the legislative history of section 1917-B, which quite

plainly indicates that the Maine Legislature, in enacting the section in 2015, see 2015

Me. Pub. L. ch. 403, § 6, 1 did not intend to alter or diminish the Commissioner's sole

statutory authority to remove signs from public rights-of-way. See State's Opposition

to Motion to Dismiss at 5-8, citingL.D. 1592 (127th Me. Legis. 2015).

The court does not agree entirely with either side's interpretation of the statute

at issue, 23 M.R.S. § 1917-B.

The Legislature enacted section 1917-B in response to the United States Supreme Court decision in Reed v. Gilbert, 576 U.S._, 135 S. Ct. 2218 (2015), in which the court invalidated a sign ordinance that imposed stricter standards for religious signs than political signs. The predecessor to section 1917-B prohibited the removal of political signs only, see 23 M.R.S. § 1917-A (repealed 2015), so it was considered of doubtful validity in light of Reed.

4 The State is entirely correct that the statutes do not expressly authorize anyone

other than the Commissioner of Transportation to remove temporary signs in public

rights-of-way. However, it does not necessarily follow that therefore anyone else who

removes any temporary sign from a public right-of-way violates section 1917-B.

In fact, the current statutes do not expressly authorize the people who put

temporary signs in public rights-of-way to remove them. The statute repealed and

replaced by Section 1917-B did say that the prohibition on removal of political signs did

not apply to persons authorized by candidates or political committees to remove the

candidates' or committees' signs, see 23 M .R.S. § 1917-A, repealed by 2015 Me. Pub. L.

ch. 403, §5, but the new provision, section 1917-B does not contain any similar

exclusion. Section 1917-B does say that it does not apply to "a person authorized to

remove signs placed within the public right-of-way in accordance with section 1913-A,

subsection 1, paragraph L," but it does not say who is so authorized or who does the

authorizing.

The sponsors of garage sales and baked bean suppers, as well as the political

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Related

Davis Forestry Products, Inc. v. DownEast Power Co., LLC
2011 ME 10 (Supreme Judicial Court of Maine, 2011)
Reed v. Town of Gilbert
576 U.S. 155 (Supreme Court, 2015)

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State of Maine v. Kendrick, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-kendrick-mesuperct-2017.