Charles M. Martin v. Department of Corrections

Summary

The Maine Supreme Judicial Court adopted a prisoner mailbox rule for unrepresented prisoners filing Rule 80C petitions for review of Department of Corrections decisions. The court held that when a prisoner delivers the petition to prison authorities at least three days before the filing deadline and the Department delays delivery to the clerk, the petition is deemed timely filed upon delivery to prison officials. The court vacated the dismissal and remanded for reinstatement of the petition.

Holdings

1. Under the open courts provision and due process clause of the Maine Constitution, an unrepresented prisoner's Rule 80C petition is deemed filed when delivered to the Department of Corrections for mailing if the prisoner completes the prison's mailing procedures at least three days before the statutory deadline and the petition is received by the clerk after the deadline.
2. Martin's petition was timely because he delivered it to prison officials on May 18, at least three days before the May 25 deadline, and the later receipt by the clerk resulted from prison delay beyond his control.

Questions Presented

1. Whether Maine's Constitution requires application of the prisoner mailbox rule to an unrepresented prisoner's Rule 80C petition delivered to prison authorities at least three days before the filing deadline but received by the clerk after the deadline.
2. Whether the Superior Court properly dismissed Martin's Rule 80C petition as untimely and denied relief under Maine Rule of Civil Procedure 60(b).

Disposition

vacated