157 A.3d 1291
Me.2017Background
- On Nov. 26, 2015, Daniel L. Chase was cited for operating a 1997 Dodge Ram with registration expired between 30 and 150 days, and a District Court fined him $50 after a nonjury trial.
- Chase repeatedly filed motions and letters arguing his truck was not a motor vehicle, asserting sovereign-traveler theories, and requesting jury trial, court “translation” of rules, appointed counsel/“interpreter,” findings of fact and conclusions of law, and various accommodations for claimed disabilities.
- The District Court denied the jury trial and requests for translation and appointed counsel, but provided CART realtime transcription during the hearing to accommodate Chase.
- At trial Chase admitted the expired-registration offense; the court adjudicated the traffic infraction and imposed the fine.
- Chase appealed, challenging denial of a jury trial and various accommodation/merits arguments; the court affirmed the judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to jury trial in traffic infraction | Chase: Me. Const. art. I, § 20 entitles him to a jury in this civil matter | State: Traffic infractions are not subject to jury trial under statute and Maine precedent | Denied — no jury right for traffic infractions (statute and precedent) |
| Court-appointed counsel / interpreter | Chase: Requested an attorney/interpreter to assist preparation and at hearing | State: No entitlement to appointed counsel in traffic matters; translation rules for limited English do not apply | Denied — no right to appointed counsel or special translation here |
| Plain-English translation of court rules | Chase: Requested “plain street level English” versions of rules | State: No requirement to provide such alternate-language translations of rules | Denied — not required by law or rules |
| Disability accommodations (memory/back injury) | Chase: Needed ability to pause/restart and other accommodations due to injuries | State/Court: Provided CART realtime transcription to accommodate his asserted memory issue | Held — accommodations were adequate; CART provided; no error |
| Merits challenges to registration requirement | Chase: Argued court lacks authority, statute doesn’t apply, or he couldn’t legally register truck | State: Statutory scheme mandates registration and court has authority | Denied — statutory and precedential authority support registration requirement and court rulings |
Key Cases Cited
- Jeskey v. State, 146 A.3d 127 (Me. 2016) (standard for viewing evidence in traffic proceedings)
- Nugent v. State, 801 A.2d 1001 (Me. 2002) (no civil jury right for traffic infractions)
- Arnheiter v. State, 598 A.2d 1183 (Me. 1991) (traffic proceedings not entitled to jury trial)
- Anton v. State, 463 A.2d 703 (Me. 1983) (same principle regarding jury trial in traffic matters)
- Eremita v. Marchiori, 150 A.3d 336 (Me. 2016) (procedural/recording issues and standards for findings)
- Mitchell v. Judicial Ethics Comm., 749 A.2d 1282 (Me. 2000) (authority regarding promulgation of rules and judicial functions)
- York Hosp. v. Dep't of Health and Human Servs., 959 A.2d 67 (Me. 2008) (standards for findings and conclusions)
Judgment affirmed.