State v. St. Onge
2011 ME 73
| Me. | 2011Background
- St. Onge, as president of Winterwood and related entities, operated a composting facility in Lyman that discharged pollutants into a brook.
- A May 2008 consent decree required Winterwood to come into compliance; a May 2008 contempt order demanded ceasing unlicensed discharges.
- On Sept. 28, 2009, the court barred Winterwood from accepting further waste for composting.
- In Oct 2009–Mar 2010, three waste companies delivered waste to Winterwood; Winterwood’s records included a fourth company under its own name.
- April 2010 criminal contempt complaint was filed; St. Onge waived his initial appearance and demanded a jury trial, transferring to the Superior Court for a bench trial; the court instructed the case as criminal contempt under civil rules.
- At trial, the court excluded two witness offers aimed at proving knowledge or misrepresentation by a State attorney; the court found St. Onge in contempt, sentencing six months with suspension and one year administrative release, labeling the offense as Class D contempt; on appeal, the court modified the judgment to strike the Class D designation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court had subject matter jurisdiction to hear punitive contempt. | St. Onge contends lack of jurisdiction because contempt arose from a civil order. | State argues inherent and statutory authority to punish contempt; Rule 66(c) contemplates criminal procedure. | Subject matter jurisdiction established; proceed as criminal contempt under Rule 66(c). |
| Whether punitive contempt can be charged as a Class D crime and the classification was proper. | Classification as Class D was improvised or erroneous. | Rule 66(c) directs prosecution as a Class D crime; contempt not defined as Class D by rule or statute. | Classification as Class D was error but harmless; modify judgment to remove Class D designation. |
| Whether the trial court properly excluded testimony about state of mind addressing punitive elements. | Evidence of mental state could negate intent or awareness. | Evidence marginally relevant to punitive elements; exclusion did not violate due process. | Court properly excluded state-of-mind testimony; no due process violation. |
| Whether personal jurisdiction and the complaint were properly handled; any irregularity waived? | Challenge to personal jurisdiction and sufficiency of complaint. | St. Onge appeared and waived; no renewed challenge under Rule 12(b)(2). | Personal jurisdiction valid; sufficiency challenge waived. |
| Whether equitable estoppel and jury-waiver issues affect the outcome. | State misrepresented by attorney could have induced conduct. | Equitable estoppel inapplicable; no causation from misrepresentation; jury waiver was knowing. | Equitable estoppel rejected; jury waiver knowingly voluntary; judgment affirmed as modified. |
Key Cases Cited
- Windham Land Trust v. Jeffords, 2009 ME 29 (Me. 2009) (subject-matter jurisdiction and contempt authorities cited)
- Edwards v. Campbell, 2008 ME 173 (Me. 2008) (courts may enforce their own orders through contempt)
- Linscott v. Foy, 1998 ME 206 (Me. 1998) (rules governing contempt procedures and authority)
- Manter, 2001 ME 164 (Me. 2001) (contempt classification and procedures under Rule 66)
- State v. Leonard, 470 A.2d 1262 (Me. 1984) (waiver of jurisdiction defenses upon appearance)
- State v. Brown, 712 A.2d 513 (Me. 1998) (Rule 12(b)(2) waiver of irregularities)
- State v. Dadiego, 617 A.2d 552 (Me. 1992) (procedural defenses and waiver)
- State v. Ouellette, 2006 ME 81 (Me. 2006) (review of jury-trial waiver and voluntariness)
- State v. Mitchell, 2010 ME 73 (Me. 2010) (meaningful opportunity to present defense; marginal relevance)
- In re Scott S., 2001 ME 114 (Me. 2001) (harmless error standard in contempt context)