Peter Beckford v. Town of Clifton, 107 A.3d 1124

Pisgah Mountain sought Planning Board approval in 2011 to build a five‑turbine wind project in Clifton; neighboring landowners Peter and Julie Beckford opposed and appealed adverse decisions up to the Town Zoning Board of Appeals (ZBA).
On January 25, 2012, the ZBA publicly considered the Beckfords’ challenges, voted point‑by‑point to reject them, and voted to deny the appeal "in its entirety," but announced it would reconvene January 30 to issue a "Final Decision."
On January 30, 2012, the ZBA approved minutes and signed and adopted a written Notice of Final Decision and findings of fact.
The Beckfords filed a Rule 80B appeal in Superior Court on March 15, 2012 (45 days after January 30 but 50 days after January 25); defendants moved to dismiss as untimely.
The Business & Consumer Docket initially reached the merits and vacated the Planning Board’s permit approval; on appeal, the Supreme Judicial Court considered whether the Superior Court had jurisdiction because the Beckfords’ administrative appeal may have been filed after the statutory deadline.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does the 45‑day appeal period under 30‑A M.R.S. § 2691(3)(G) begin — at the public vote or issuance/adoption of a written decision?	Beckfords: the period begins when the ZBA issued/adopted its written findings (Jan. 30).	Pisgah/Town: the period begins at the ZBA's public, final vote (Jan. 25).	The Court held the statute’s plain language starts the appeal period at the board’s public vote; written findings are distinct and need not accompany the vote.
Which ZBA action was the operative "vote on the original decision" — Jan. 25 vote or Jan. 30 adoption of the written notice?	Beckfords: Jan. 30 was the final vote adopting the written decision; thus appeal was timely.	Pisgah/Town: the Jan. 25 vote was public and final in disposing of the appeal; Jan. 30 only formalized the already made decision.	The Court held the Jan. 25 public vote was the operative event; the Beckfords’ Rule 80B appeal filed March 15 was therefore untimely and deprived the Superior Court of jurisdiction.

Davric Maine Corp. v. Bangor Historic Track, Inc., 751 A.2d 1024 (Me. 2000) (statutory appeal periods are jurisdictional)
Carroll v. Town of Rockport, 837 A.2d 148 (Me. 2003) (appeal period runs from the board’s final vote, not later issuance of written findings)
Vachon v. Town of Kennebunk, 499 A.2d 140 (Me. 1985) (board’s vote constitutes rendering of decision for appeal timing despite later mailing of written notice)
Woodward v. Town of Newfield, 634 A.2d 1315 (Me. 1993) (appeal period commences at the public vote because it is definite and publicly known)
Gorham v. Androscoggin County, 21 A.3d 115 (Me. 2011) (distinguishing circumstances where written findings control timing; clarified interaction with Rule 80B)
Fournier v. Dep’t of Corrs., 983 A.2d 403 (Me. 2009) (appeal deadlines are jurisdictional and failure to meet them mandates dismissal)