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Prisoner Education Guide

Maine: Superior Court’s Dismissal for Lack of Jurisdiction Not Supported by the Record

by Dale Chappell

A sua sponte dismissal for lack of jurisdiction by a state Superior Court was improper, the Maine Supreme Judicial Court held on April 19, 2018, when the record was “otherwise devoid” of any indication the Superior Court lacked jurisdiction in the case.

Steve Anctil, a state prisoner, filed a pro se petition under Maine Rule of Civil Procedure 80C, seeking review of a disciplinary decision by the Department of Corrections (DOC). He argued that the DOC committed several procedural and constitutional errors, and asked the Superior Court to vacate the DOC’s decision and award damages. Anctil also filed an application to proceed without payment of fees, with an attached certificate of his prison trust account.

The Superior Court, however, was not inclined to hear the case. Without any input from the DOC and on its own initiative, the Court dismissed Anctil’s petition with a single sentence: “After review of the pleadings the Court orders: case dismissed for lack of jurisdiction.” The Court did not indicate why it lacked jurisdiction, and Anctil appealed.

A court may dismiss a case for lack of jurisdiction only when it is clear from the petition, or when a party raises the jurisdictional defect. However, when a petition states a claim for relief that “facially meets statutory requirements,” that is sufficient to establish jurisdiction, the Supreme Judicial Court held. It also found that a petitioner’s failure to strictly comply with technical requirements does not automatically deprive a court of jurisdiction, citing Mutty v. Dept. of Corr., 153 A.3d 775 (Maine 2017) and Fleming v. Dept. of Corr., 796 A.2d 692 (Maine 2002).

“No jurisdictional defect is apparent from the record here,” the Supreme Judicial Court concluded in Anctil’s case. As was true in Mutty, which was decided just months before Anctil filed his appeal, the Superior Court’s sua sponte dismissal was in error. Accordingly, the case was remanded to allow his complaint to proceed. See: Anctil v. Dept. of Corr., 2018 ME 53, 183 A.3d 760 (Maine 2018). 

 

Related legal case

Anctil v. Dept. of Corr.


 

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Disciplinary Self-Help Litigation Manual