Vt. Fed. Sportsmen v. Birmingham

CourtVermont Superior Court
DecidedMay 14, 2020
Docket224-4-18 Wncv
StatusPublished

This text of Vt. Fed. Sportsmen v. Birmingham (Vt. Fed. Sportsmen v. Birmingham) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vt. Fed. Sportsmen v. Birmingham, (Vt. Ct. App. 2020).

Opinion

Vt. Fed. Sportsmen v. Birmingham, No. 224-4-18 Wncv (Tomasi, J., May 14, 2020).

[The text of this Vermont trial court opinion is unofficial. It has been reformatted from the original. The accuracy of the text and the accompanying data included in the Vermont trial court opinion database is not guaranteed.]

STATE OF VERMONT SUPERIOR COURT CIVIL DIVISION Washington Unit Docket No. 224-4-18 Wncv

Vermont Federation of, Vermont State Rifle & Pistol, Powderhorn Outdoor Sports, John Fogarty, Samuel Frank, Plaintiffs

v.

Matthew Birmingham, T.J. Donovan, Sarah George, William Porter, Defendants

Opinion and Order on Motion for Permission to Appeal Under Vt. R. App. P. 5.1

This matter has a robust procedural history. The case concerns the

constitutionality of 13 V.S.A § 4021, which limits the size of the magazines that can

be used in firearms. The State moved to dismiss, and the Plaintiffs moved for

summary judgment. The Court denied both motions. It concluded that it would not

decide the case on so-called “legislative facts” but would require the parties to

develop a factual record on which the constitutional claim could be adjudicated. At

around the same time another action, arising in Bennington County—State v.

Misch, 173-2-19 Bncr—was decided and appealed to the Vermont Supreme Court.

That decision concluded that Section 4021 is constitutional.

1 The parties filed a joint motion for permission to appeal. For similar reasons

as noted in the denial of the earlier motions, the Court denied that request as well.

Despite the happy unity of opinion among the parties at that point, they did not

seek review in the Supreme Court of the denial of the request for interlocutory

appeal. Vt. R. App. P. 5(b)(7).

As an alternative to appeal, the State also sought a stay of this matter

pending resolution of the Misch matter. The Court denied the request without

elaboration. The State sought reconsideration of the denial of the stay request, and,

in the alternative, sought permission to appeal the denial under Vt. R. App. P. 5.1.

The Court denied reconsideration, again, indicating its belief that development of a

factual record in this matter would be important to decide the issues presented. It

denied the request to appeal as being untimely.

The State proceeded to seek review of the denial in the Supreme Court. The

High Court concluded that the State’s request for permission to appeal was not

untimely. It remanded to this Court to consider the State’s request to appeal this

Court’s denial of the request for a stay.

In light of the foregoing, it is worth noting what is not before the Court. The

Court is not tasked with determining whether to grant permission to appeal the

merits of the constitutional issue under Appellate Rule 5, nor is it being asked to

determine whether to stay this matter. The sole question sub judice is whether the

Court’s earlier denial of the request to stay should be deemed a collateral final order

under Vt. R. App. P. 5.1.

2 Under that Rule:

[T]he superior court may permit an appeal from an interlocutory order or ruling if the court finds that the order:

(A) conclusively determines a disputed question;

(B) resolves an important issue completely separate from the merits of the action; and

(C) will be effectively unreviewable on appeal from a final judgment.

Vt. R. App. P. 5.1(a)(1).

The State’s argument is straightforward: the denial of the stay was

definitively decided by the Court and confirmed on reconsideration, it is a matter

separate from the merits, and it cannot be reviewed upon later appeal. The State

further contends that the equities of the case also favor allowing it to seek a stay

from the Supreme Court. It maintains that there is a strong likelihood that the

Misch appeal will decide or, at least, clarify the constitutional issue, that forcing the

parties to engage in costly and lengthy discovery could amount to a significant

waste of both public and private resources, and that engaging in summary

judgment and trial practice in this matter could also amount to a waste resources,

including judicial resources. For their part, the Plaintiffs maintain that it is

possible that the Misch case could resolve through a plea agreement short of a

decision and that delaying resolution of this case impacts their constitutional rights.

The State is correct that the decision denying the requested stay appears to

meet the standards set out in Rule 5.1. The same argument, however, could be

made with regard to any decision regarding a request to stay proceedings. The

3 Court does not believe Rule 5.1 envisioned that such procedural rulings would

customarily fall within the scope of collateral final order appeals. See Charles

Wright, Arthur Miller & Edward Cooper, 15A Fed. Prac. & Proc. Juris. § 3911.4 (2d

ed. 2019) (“Similarly plausible arguments could be made—usually without

success—that various procedural devices [including stays] or substantive doctrines

are intended to protect against the burdens of trial.”) [hereinafter Fed. Prac. &

Proc.].

In any event, even if the stay decision technically meets the components of

the Rule, the Court still has discretion as to whether to allow the appeal. Rule 5.1

was specifically amended to make clear that courts “may” permit appeals of

collateral final orders. Vt. R. App. P. 5.1, Reporter’s Notes—1990 Amendment. In

making that determination, the Court is guided by the following:

While we set forth specific criteria without which a collateral order will not be reviewed by this Court, overriding these threshold criteria is our need to balance the possible loss of important rights “against this Court’s policy of avoiding piecemeal review.” 148 Vt. at 292, 532 A.2d at 562. Lafayette should not be read as an addendum to the Vermont Rules of Appellate Procedure, creating a virtual entitlement to review of collateral orders. Lafayette offers appellate redress in the small number of extraordinary cases where the normal appellate route will almost surely work injustice, irrespective of this Court’s final decision. Petitions like those at bar would convert the extraordinary into the ordinary and hamper not only the work of this Court, but the orderly processes of trial courts and administrative bodies as well. Lafayette announced a procedure that will be available when strong need is demonstrated. But it must not be seen as a commonplace alternative to normal appellate review under our rules.

In re Maple Tree Place Assocs., 151 Vt. 331, 332–33 (1989); see Fed. Prac. & Proc. §

3911.4 (collateral final appeal available concerning stays “on showing special

4 justification”); Rivere v. Offshore Painting Contractors, 872 F.2d 1187, 1190 (5th Cir.

1989) (allowing appeal of order staying benefit payments as collateral final order).

Under the unique circumstances of this case, the Court believes the denial of

the request to stay constitutes a “special justification” that warrants appeal under

Rule 5.1. The Misch litigation appears to be on all fours with the present case and

the briefing has already begun. It is highly likely that the Court’s ruling will

resolve this case. Alternatively, the Court’s ruling would clarify the areas where

factual development may be necessary. The Court agrees that pursuing unbridled

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Related

In re Maple Tree Place Associates
560 A.2d 382 (Supreme Court of Vermont, 1989)
Rivere v. Offshore Painting Contractors
872 F.2d 1187 (Fifth Circuit, 1989)

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Vt. Fed. Sportsmen v. Birmingham, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vt-fed-sportsmen-v-birmingham-vtsuperct-2020.