133 A.3d 1006
Me.2016Background
- Somerset County operated the Somerset County Jail (SCJ); FY2013 budget approved by State Board of Corrections (the Board) included expected revenue from federal prisoner boarding and State Investment Fund payments but excluded debt service.
- County received substantially more federal boarding revenue than budgeted in FY2013 and, by county resolution (Resolution 13-007), applied 75% of the surplus to jail debt service and 25% to a jail capital improvement fund without Board approval.
- The Board learned of the County’s unilateral allocation, anticipated a State Investment Fund shortfall, and withheld the County’s third-quarter disbursement of $280,442 from the State Investment Fund.
- Somerset County appealed the Board’s withholding to the Superior Court under M.R. Civ. P. 80C; the Superior Court vacated the Board’s decision.
- On appeal, the Supreme Judicial Court addressed statutory interpretation whether federal boarding revenue fell within the coordinated corrections financial scheme and whether the Board could amend disbursements; during the appeal the Board was abolished and the Department of Corrections (DOC) was substituted as defendant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Board could withhold State Investment Fund disbursement after County applied surplus federal boarding revenue to jail debt without Board approval | County: Board lacked authority to control federal boarding revenue; County could allocate it to debt service | Board/DOC: Board has statutory authority to oversee county correctional budgets and may amend disbursements to address unauthorized use of correctional funds | Held for Board/DOC — Board permissibly amended budget and withheld payment as necessary to offset County’s unauthorized use of funds; judgment remanded for DOC judgment |
| Whether federal boarding revenue constitutes “correctional services funds” subject to statutory restrictions and Board control | County: Federal boarding fees are not municipal assessments nor part of the State Investment Fund and therefore are not subject to Board control | Board/DOC: Federal boarding revenue funds correctional services and fall within the coordinated system the Board controls (budget revenues and expenditures) | Held: Court interprets statutory scheme to allow Board control — revenues generated by providing correctional services fit within the system and are subject to Board oversight; County’s unilateral diversion contravened the scheme |
| Whether substitution of DOC for the abolished Board preserves justiciability and allows relief | County: DOC should be substituted because responsibilities (and funds) transferred to DOC when Board abolished | DOC: Disputed creation of any reserve and contended fund transfers didn’t permit satisfying County claims | Held: Substitution granted — Sheriff’s affidavit and statutory carryforward created sufficient basis to substitute DOC and preserve justiciability |
Key Cases Cited
- Merrill v. Me. Pub. Emps. Ret. Sys., 98 A.3d 211 (Me. 2014) (standard of review and deference to agency interpretations)
- Skolnick v. Kemer, 435 F.2d 694 (7th Cir. 1970) (abatement of suits when a dissolved agency has no successor)
- MacImage of Me., LLC v. Androscoggin Cty., 40 A.3d 975 (Me. 2012) (use of subsequent statutory changes to interpret prior legislative intent)
- Paradis v. Town of Peru, 115 A.3d 610 (Me. 2015) (agencies have only statutory powers conferred or necessarily implied)
- Carrier v. Sec'y of State, 60 A.3d 1241 (Me. 2012) (issues not raised administratively are generally unpreserved on appeal)