State of Maine v. O'Connell

CourtSuperior Court of Maine
DecidedJune 9, 2023
DocketANDap-23-05
StatusUnpublished

This text of State of Maine v. O'Connell (State of Maine v. O'Connell) 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. O'Connell, (Me. Super. Ct. 2023).

Opinion

STATE OF MAINE SUPERIOR COURT ANDROSCOGGIN, ss. CIVIL ACTION DOCKET NO. AP-23-05

STATE OF MAINE,

Appellee

V. ORDER DENYING APPEAL

KATHLEEN O'CONNELL,

Appellant

The matter before the court is appellant Kathleen O'Connell's appeal of two District

Court orders in different animal welfare proceedings related to the seizure of cats from her

property.

Background

The following facts could have been found by the District Court.

The disputes between Ms. O'Connell and the State's Animal Welfare Program ("AWP")

go back several years. The first legal action occurred on November 5, 2019, when the A WP

executed a warrant and seized 82 of Ms. O'Connell's cats. The District Court (Dow, J), in a case

docketed at CV-19-448, ordered the A WP to return these cats on September 15, 2020, after

finding that Ms. 0' Connell had not violated permissible standards of care for the cats. The

District Court ordered the AWP to return the cats to Ms. O'Connell "as soon as it [could]

reasonably be arranged, consistent with the health and safety of the cats."

The AWP began the process of returning the cats with some expediency. On October 26,

2020, the State returned several cats, and many more on November 6. After November 6, the

A WP believed that it had returned all of the cats that it could return safely, as the nine cats that it

withheld were sick and required veterinary care. Ms. 0' Connell alleged, and continues to allege,

1 that the State actually withheld eighteen cats. The AWP refused to return the sick cats to Ms.

O'Connell before receiving a management plan from her with provisions for their care, which

Ms. O'Connell did not provide.

On June 7, 2021, Ms. O'Connell filed a Motion to Enforce in the case docketed at CV­

19-448. Ms. O'Connell alleged that the AWP had failed to comply with the September 15 Order

by failing to return eighteen cats. The AWP opposed the motion, arguing that it had only

withheld nine cats, and that those nine sick cats had been withheld pursuant to the District

Court's instruction that the cats be returned to Ms. O'Connell "consistent with the health and

safety of the cats."

In January 2022, while the motion to enforce was pending, a complaint was made to the

AWP regarding the animal population maintained on Ms. O'Connell's property. On or about

January 10, 2022, while Ms. O'Connell and her father were in the hospital with COVID-19, Ms.

O'Connell's brother, Thomas O'Connell, Jr., entered the home at 222 Ridge Road, Wales, where

Ms. O'Connell lives. Mr. O'Connell was checldng for frozen pipes and to make sure there was

water in the tank for the furnace. Mr. 0' Connell testified before the District Court that he and his

wife observed the home to be in a state of"unkept squalor." When Mr. O'Connell entered the

home again four days later, he found dead cats in the home. This prompted Mr. 0 'Connell to call

animal control.

Ms. O'Connell was in the hospital for both of Mr. O'Connell's visits to the 222 Ridge

Road home. Ms. O'Connell later claimed that Mr. O'Connell's entry into the home was illegal,

but he testified that he had never needed permission to enter the home before, which belonged to

his father. Ms. O'Connell was discharged from the hospital on January 20, 2022.

2 Angela Rogers, a District Humane Agent for the A WP, applied for and was granted a

search wmrnnt for 222 Ridge Road, Wales, Maine, where Ms. O'Connell lives. The search

warrant was seeking "evidence of the crime of crnelty to animals, including but not limited to,

any live, dead or unborn animals which have been found to be deprived of necessary sustenance,

necessary medical care, proper shelter, protection from the weather and/or humanely clean

conditions ...."

The A WP executed the search warrant on January 28, 2022. The A WP sought and was

granted a second search wan-ant that authorized an extended search period from Febrnary 2 to

February 4, 2022. The AWP seized 111 cats during the search, 33 of which were found deceased.

In addition, the A WP seized 26 poultry.

On March 8, 2022, the A WP filed an Application for a Possession Order and Order to

Show Cause, pursuant to 17 M.R.S. § 1021 (3), which was docketed at CV-22-75. The District

Court consolidated the Application for a Possession Order (CV-22-75) and the Motion to

Enforce (CV-19-448). A consolidated hearing was held on April 13, April 26, and June 2, 2022.

The District Court heard the Motion to Enforce on the first day, and the Application for a

Possession Order on the other two days.

The District Court (Driscoll, J) granted the State's Application for a Possession Order,

finding that the animals in Ms. O'Connell's care "suffered from disease, dehydration, and

malnourishment, and were deprived of necessary medical attention and humanely clean

conditions." (Order~ 11.) While the District Court found that Ms. O'Connell is kind-hearted and

loves these cats, it also found that she "is in denial about the condition of scores of these animals

who suffered, and in many cases, died, in her care." (Id.~ 9.) The District Comt ruled that Ms.

0' Connell had failed to show cause why the animals should not be seized permanently or

3 disposed of humanely, as is required under 17 M.R.S. § 1021 (3). Accordingly, the District Court

ordered that the animals "are hereby forfeited and the applicant or other suitable person may take

possession and provide for the animals or order their sale, adoption or placement." (Id. at order.)

The District Coutt also ruled on Ms. O'Connell's Motion to Enforce on the same day,

granting it in part and denying it in part. The Dish-ict Court held that A WP wrongly interpreted

the prior order as giving it the authority to withhold the nine sick cats and ordered that they be

returned. At the same time, the District Court held that Ms. 0' Connell did not meet her burden of

proof to establish that nine other cats had been withheld. The District Coutt found the witnesses

for the State credible, which testified that all cats seized were returned except for the nine sick

cats in dispute.

Ms. O'Connell appealed both orders to the Superior Coutt.

Discussion

Ms. O'Connell raises many arguments in support of her appeal. The court addresses each

of the substantive arguments below, though not necessarily in the same order as Ms. O'Connell

presented them in her brief.

Res Judi cata

Ms. O'Connell's first substantive argument is that the District Court erred by ente1taining

the Application for a Possession Order, which she claims should have been barred by the District

Court's September 15, 2020 order requiring A WP to return the cats seized on November 5, 2019

under the doctrine of res judicata.

"The doctrine of res judicata prevents the relitigation of matters already decided in order

to promote judicial economy and efficiency, the stability of final judgments, and fairness to

litigants." Estate a/Treworgy v. Comm'r, Health and Human Servs., 2017 ME 179, 111, 169

4 A.3d 416 (quotations and citations omitted). The doctrine consists of two components, issue

preclusion and claim preclusion. Portland Water Dist. v.

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State of Maine v. O'Connell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-oconnell-mesuperct-2023.