Somerset County v. Department of Corrections

Summary

The Maine Supreme Judicial Court held that the former Maine State Board of Corrections had authority to control Somerset County's use of surplus federal prisoner boarding revenue and to withhold corresponding State Investment Fund payments. The Court concluded that the County's unilateral application of the revenue to jail construction debt was inconsistent with the statutory coordinated corrections system. The Court vacated the Superior Court's judgment and remanded for entry of judgment in favor of the Department of Corrections, which was substituted for the abolished Board.

Holdings

1. The Department of Corrections was properly substituted for the abolished State Board of Corrections because the abolishing legislation transferred relevant responsibilities and funds to the Department, preserving the justiciability of the action.
2. Somerset County did not fail to exhaust administrative remedies because it presented its position to the Board, which had an opportunity to consider and act on it, and the Board identified no established procedure requiring a further response to its ad hoc invitation.
3. Under the statutory scheme in effect during fiscal year 2013, revenues generated by boarding federal prisoners constituted correctional services funds and were subject to the Board's control; Somerset County could not unilaterally apply surplus federal boarding revenue to jail construction debt without Board approval.
4. The Board acted within its statutory authority and did not abuse its discretion when it withheld the third-quarter State Investment Fund payment to offset the County's unauthorized use of surplus federal boarding revenue.

Questions Presented

1. Whether the abolished State Board of Corrections could be replaced by the Department of Corrections so that the dispute remained justiciable.
2. Whether federal prisoner boarding revenue constituted correctional services funds subject to the statutory coordinated-corrections scheme.
3. Whether the Board of Corrections had authority to control the County's disposition of surplus federal boarding revenue and to amend the County's correctional budget by withholding a State Investment Fund disbursement.
4. Whether the County failed to exhaust administrative remedies by not responding to the Board's additional invitation to submit argument.

Disposition

reversed_and_remanded