36 A.3d 888
Me.2012Background
- Mrs. T. appeals a final judgment affirming the denial of her grievance seeking waiver eligibility for her son C.T.
- C.T. is a fifteen-year-old with severe disabilities requiring continuous one-to-one supervision, placed in a New Hampshire residential facility at the Department’s initial direction.
- Department employees advised Mrs. T. that C.T. was grandfathered under the waiver, creating a belief of ongoing eligibility.
- A regulatory change effective December 30, 2007 ended waiver eligibility for minors; the status of C.T. was not updated for years.
- Between 2005 and 2007 the Department attempted to find a Maine placement but faced funding and regulatory constraints, hindering placement efforts.
- In 2009 Mrs. T. learned C.T. was no longer waiver-eligible and sought funding for a Lewiston placement; the waiver ultimately could not fund it.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether equitable estoppel lies against the government under these facts | T. relies on misrepresentations to prove detrimental reliance | No causal link between misinformation and C.T.’s ineligibility | Estoppel not applicable; no detrimental reliance proven |
Key Cases Cited
- Dep’t of Health and Human Servs. v. Pelletier, 2009 ME 11 (Me. 2009) (estoppel requires proof of detrimental reliance with caution in government actions)
- Mathieu v. Comm’r of Human Servs., 562 A.2d 686 (Me. 1989) (estoppel burden on the claimant; high bar against government)
- Hart v. County of Sagadahoc, 609 A.2d 282 (Me. 1992) (governmental estoppel is limited; not as broad as private party)
- Trull Nursing Home, Inc. v. Dep’t of Human Servs., 461 A.2d 490 (Me. 1983) (warns against broad application to public fisc)
- Tenants Harbor Gen. Store, LLC v. Dep’t of Envtl. Prot., 2011 ME 6, 10 A.3d 722 (Me. 2011) (appellate review of estoppel standards in agency actions)