Martin v. Department of Corrections

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The “prisoner mailbox rule” applies when a prisoner is forced to rely on the Department of Corrections to ensure that his Me. R. Civ. P. 80C petition is filed, that prisoner places the petition into the control of the Department, and the Department fails timely to deliver the petition to the clerk of court.Petitioner signed a petition pursuant to Me. Rev. Stat. 5, 11002 for judicial review of a Department decision finding that he had committed a disciplinary infraction. The State moved to dismiss the petition for failure to state a claim, arguing that because the clerk of court received Petitioner’s petition one day outside of the thirty-day statutory window, the superior court lacked jurisdiction over the matter. Petitioner urged the superior court to apply the prison mailbox rule, whereby the court would consider the petition filed on the date Petitioner deposited it with prison officials for forwarding to the clerk of court rather than the day it was received by the clerk of court. The court granted the State’s motion to dismiss. After setting forth the circumstances above under which the prisoner mailbox rule applies the Supreme Judicial Court adopted the prison mailbox rule for any unrepresented prisoner under the circumstances of this case, vacated the judgment, and remanded to the superior court for reinstatement of the Rule 80C petition. View "Martin v. Department of Corrections" on Justia Law