Background

• Blackhouse filed a protection from abuse complaint against Jane Doe on May 6, 2010 alleging stalking and related behaviors and health deterioration.
• He also submitted a request for reasonable accommodation claiming PTSD and asking to proceed without entering the court premises.
• The district court denied his ex parte temporary order; it is unclear if the accommodation request was considered at that stage.
• A final hearing was scheduled for May 24, 2010; Blackhouse did not appear and the court dismissed the complaint.
• Blackhouse appealed, arguing the court should have considered his accommodation request; the appellate court vacated the dismissal and remanded for action on the accommodation request.
• The decision emphasizes that reasonable accommodation must be considered before concluding the merits of an abuse claim and before final disposition.

Issues

Key Cases Cited

• Lane v. Brown, 541 U.S. 509 (U.S. 2004) (ADA reasonable modifications to ensure meaningful access to courts)
• Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility standard for complaints)
• Scott v. Harris, 550 U.S. 372 (U.S. 2007) (court may terminate proceedings on implausible stories)
• Boggs v. Berthiaume, 2008 ME 169 (Me. 2008) (courts may sanction frivolous or vexatious actions)
• Spickler v. Key Bank of So. Me., 618 A.2d 204 (Me. 1992) (potential to bar further claims for frivolous actions)
• Jusseaume v. Ducatt, 2011 ME 43 (Me. 2011) (right to confront accusers and evidentiary due process in abuse actions)
• Lane v. City of Portland, 508 A.2d 948 (Me. 1986) (state duties of accommodation and accessibility)
• Suzman v. Comm'r, Dep't of Health & Human Servs., 2005 ME 80 (Me. 2005) (accommodation principle in state context)
• Me. Human Rights Comm'n v. City of S. Portland, 508 A.2d 948 (Me. 1986) (state civil rights considerations in accommodations)