State of Maine v. Lluvera

CourtSuperior Court of Maine
DecidedDecember 20, 2018
DocketCUMcr-18-20619
StatusUnpublished

This text of State of Maine v. Lluvera (State of Maine v. Lluvera) 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. Lluvera, (Me. Super. Ct. 2018).

Opinion

STATE OF MAINE UNIFIED CRIWNAL COURT CUMBERLAND, ss. ,. PORTLAND .; ·' ·Docket Nos. CR-18-20619 CR-18-06132 CR-18-20450

STATE OF MAINE ) ) ORDER ON COMMISSIONER'S ) MOTION TO DISWSS V. ) DEFENDANT'S MOTION ) FOR CONTEMPT ) JOSEPH LLUVERA ) ) Defendant )

The court found Mr. Lluvera to be incompetent to stand trial on various criminal

charges by Order ["IST Order"] dated November 9, 2018. The 1ST Order states in

pertinent part that Defendant shall "be col!lmitted to the custody of the Commissioner of

Health and Human Services for placement in an appropriate program for observation,

care and treatment of people with mental illness or persons with intellectual disabilities

or autism .... At the end of 30 days or sooner, and again in the event of recommitment, at

the end of 60 days and 180 days, the State Forensic Service or other appropriate office of

the Department of Health and Human Services shall forward a report to the

Commissioner of Health and Human Services relative to the defendant's competence to

stand trial and its reasons .... "

Concerned that her client, Mr. Lluvera, still remained in the Cumberland County

Jail for weeks following the 1ST Order, on November 28, 2018 Attorney Sarah Branch filed

an Emergency Motion for Contempt and Other Proceedings against the Commissioner of

Health and Human Service, alleging that the Commissioner "refuses to accept Defendant

as a patient at its facilities" in violation of the 1ST Order. Attorney Branch filed an

Amended Emergency Motion for Contempt on November 30, 2018 which included the

notarization required by M.R. Civ. P. 66(d)(2)(A). The Commissioner filed an Answer and Objection to and Motion to Dismiss Amended Motion for Contempt on December 10,

2018.

The court heard oral argument on the Commissioner's Motion to Dismiss on

December 13, 2018. Assistant Attorney General Molly Moynihan appeared and argued 1

--..., --­ on behalf of the Commissioner. Assistant District Attorney_j\manda Doh:E...ty appeared

and argued, representing the State's interest in the underlying criminal proceedings.

·----- Attorney Sarah Branch appeared and argued on behalf of Defendant.

It is not disputed that Mr. Lluvera was admitted to the Riverview Psychiatric

Center on December 4, 2018. Because Mr. Lluvera obtained a bed at Riverview as of

December 4, 2018, the Commissioner contends that Mr. Lluvera has already obtained the

remedy sought such that his contempt motion is moot and should be dismissed.

At hearing, while conceding that Mr. Lluvera has obtained the remedy sought,

Attorney Branch urged the court to reach the merits of the contempt motion regardless

of Mr. Lluvera' s admission to Riverview. She asked the court to reach the merits pursuant

to the "public interest" exception to the mootness doctrine. Citing the importance of the

issues at stake and decrying the pervasive shortfall in much-needed psychiatric services

in Maine, Attorney Branch insisted that the court has the authority under Rule 66 to

enforce the court's 1ST Order. According to her argument, the court should allow

Defendant's motion for contempt to go forward to send a message to the Commissioner

that such delays in accepting court-ordered custody of mentally incompetent individuals

are egregious and will not be tolerated.

1The court agreed with the Commissioner that a hearing on the merits of Defendant's Motion to Contempt and on the merits of the Commissioner's Motion to Quash Subpoena should be continued until after the court resolved the Motion to Dismiss.

2 Delay in the treatment of the mentally ill, especially those who have been brought

into Maine's criminal justice system, is of great concern to the court. However, Rule 66

is limited in scope to remediation with respect to present failures or refusals to comply

with court orders. Attorney Branch asserted at hearing that Defendant is seeking a

"plenary proceeding for remedial sanctions" pursuant to M.R. Civ. P. 66(d). A "remedial

sanction" is a sanction "imposed to coerce the termination of an ongoing contempt or to

compensate a party aggrieved by contempt." See M.R. Civ. P. 66(a)(2)(C). The remedy

sought by Mr. Lluvera - a bed at Riverview - has already been obtained. The "public

interest" exception to the mootness doctrine authorizes an appellate court to reach an

appeal; it does not extend to trial courts, which are charged with adjudicating a live

controversy. See, e.g., In re Faucher, 558 A.2d 705, 706 (Me. 1989) ("courts should decline

to decide issues which by virtue of valid and recognizable supervening circumstances

have lost their controversial vitality. Such cases are moot"); Young v. Young, 2002 ME 167,

narrow, yet established, exceptions to the mootness doctrine applies: 1) sufficient

collateral consequences will flow from a determination of the questions presented, 2) the

question, although moot in the immediate context, is of great public interest and should

be addressed for future guidance of the bar and public, or 3) the issue may be repeatedly

presented to the trial court, yet escape review at the appellate level because of its fleeting

or determinate nature.") (emphasis added). Thus, regardless of the significant public

interest at stake, the court has no authority under Rule 66 to adjudicate Mr. Lluvera's

Motion for Contempt, since that motion was rendered moot when Mr. Lluvera obtained

a bed at Riverview on December 4, 2018.

Aside from the mootness issue, the court makes no ruling at this time on whether

or not a motion for contempt is an appropriate vehicle for relief in cases such as this one.

3 However, Rule 66 expressly provides that in order to find an individual in contempt, the

movant must show by clear and convincing evidence that the alleged contemnor both

Jailed to follow a court order and that he or she failed to follow a court order despite having

had the ability to do so. See M.R. Civ. P. 66(d)(2)(D) ("In order to make a finding of contempt, the court must find by clear and convincing evidence that: i) the alleged contemnor has

failed or refused to perform an act required or continues to do an act prohibited by a court

order, and ii) it is within the alleged contemnor's power to perform the act required or

cease performance of the act prohibited"). See also York Register of Probate v. York County

Probate Court, 2004 ME 58,

enforce administrative matters); 5 M.R.S. § 11001(2) ("Any person aggrieved by the

failure or refusal of an agency to act shall be entitled to judicial review thereof in the

Superior Court. The relief available in the Superior Court shall include an order requiring

the agency to make a decision within a time certain").

It is accordingly hereby ORDERED that the Commissioner's Motion to Dismiss

Amended Emergency Motion for Contempt is GRANTED. All other pending motions

relating to this contempt proceeding are likewise dismissed as moot.

DATED: Ju (µ.,G, ) q Jed J. ·ench Unifi d Criminal Court Judge

4 STATE OF MAINE CRIMINAL DOCKET v. CUMBERLAND, ss.

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Related

Young v. Young
2002 ME 167 (Supreme Judicial Court of Maine, 2002)
In Re Faucher
558 A.2d 705 (Supreme Judicial Court of Maine, 1989)
York Register of Probate v. York County Probate Court
2004 ME 58 (Supreme Judicial Court of Maine, 2004)

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State of Maine v. Lluvera, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-lluvera-mesuperct-2018.