Opposition Brief — Hannaford Bros. v. Ciampi

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No. 96-655

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In The

Supreme Court of the United States

October Term, 1996

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HANNAFORD BROS. CO.,

Petitioner,

THERESA CIAMPI,

Respondent.

On Petition For A Writ Of Certiorari

To The Supreme Judicial Court Of Maine

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BRIEF IN OPPOSITION

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James J. MacApAmM

McTeacus, Hicsee, MAcApaM,

Case, WaTsON & COHEN

Four Union Park

P.O. Box 5000

Topsham, ME 04086-5000

(207) 725-5581

For Respondent

COCKLE LAW BRIEF PRINTING CO., (800) 225-6964

OR CALL COLLECT (402) 342-2831

i

QUESTION PRESENTED

Whether a provision of a state workers’ compensa-

tion statute requiring an employer to include the value of

an injured worker’s discontinued fringe benefits in deter-

mining the worker’s pre-injury average weekly wage,

upon which the workers’ compensation benefit rate is

based, but not imposing legal, structural or benefit

requirements on any ERISA-covered employee benefit

plan “relates to” such a plan within the meaning of

ERISA’s preemption provisions.

ii

TABLE OF CONTENTS

QUESTION PREGEN ERG: 6 oo scriece es 8 eckeoes veers i

CSPEINE: DORAFEN 145s pees baverueeceaetun eeeek es 1

STATUTORY PROVISIONS INVOLVED............. 1 |

REASONS FOR DENYING THE WRIT............. 2

I. THE DECISION BELOW IS CONSISTENT

WITH THE CONGRESSIONAL INTENT

UNDERLYING ERISA AND POSES NO

THREAT TO REGULATORY UNIFORMITY... 4

Il. THE DECISION BELOW WAS CORRECT ON

THE MERITS BECAUSE IT UNDERSTOOD

AND PROPERLY APPLIED THIS COURT’S

RECENT HOLDINGS IN GREATER WASH-

INGTON BOARD OF TRADE AND BLUE |

CROSS AND CORRECTLY FOUND IN LIGHT

OF THOSE HOLDINGS THAT THE CHAL- |

LENGED MAINE LAW HAS ONLY A “TEN- |

UOUS, REMOTE OR PERIPHERAL”

RELATIONSHIP TO ERISA PLANS THAT

DOES NOT WARRANT A FINDING OF ERISA

PREEMPTION......... ra kad ebb CRONE DROS 9

CA FING AURA ho 6 bes Co red cheeses cberer rercns ewes 14

STATEMENT OF THEE. CADE F035 6ac Sev sc pieide tec eaes 1 |

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TABLE OF AUTHORITIES

Page

Cases

Ciampi v. Hannaford Bros. Co., 681 A.2d 4 (Me.

RE TGS GR Sy pe erry ees a eee) Pe ae ee 2

Combined Management, Inc. v. Superintendent of the

Bureau of Ins. of State of Me., 22 F.3d 1 (1st Cir.

1994), cert. denied, 115 S.Ct. 350, 130 L.Ed.2d 306...5,

District of Columbia v. Greater Washington Board of

Trade, 506 U.S. 125, 113 S.Ct. 580, 121 L.Ed.2d

3 Pe peer a eee ee pee 4, 3, 4 6; 11,

Fort Halifax Packing Co. v. Coyne, 482 U.S. 1, 107

Te eo RR ES Bt a ee ae

Guidry v. Sheet Metal Workers Nat. Pension Fund, 39

Pee Wee BREE Ge AOE a bah ch ca dvicavebcre bess.

Hook v. Morrison Milling Co., 38 F.3d 776 (5th Cir.

ee Ga Cin ny pk kde he hdaer ed op de Eads nop

Ingersoll-Rand Co. v. Perry McClendon, 498 U.S. 133,

111 S.Ct. 478, 112 L.Ed.2d 474 (1990) ........... 5,

Keystone Chapter Assoc. Builders v. Foley, 37 F.3d

945 (3rd Cir. 1994), cert. denied, 115 S.Ct. 1393

NN Ee SCRE hae PKS OE CURD AES 08 NEW OLAS bod 0 U9 8 ‘;

Lawrence Paper Co. v. Gomez, 257 Kan. 932, 897 P.2d

134 (1995), cert. denied, 116 S.Ct. 187, 133

Se Se RUE eed ek beatae neta ehh ds oan bo aos

New York State Conf. of Blue Cross, ___ U.S. __, 115

ee Ne Lay ey Loukas bos 3,

Raymond v. Mobil Oil Corp., 983 F.2d 1528 (10th Cir.

1993), cert. denied, 510 U.S. 822, 114 S.Ct. 81, 126

a i a ele eee eens es 5,

Shaw v. Delta Air Lines, Inc., 463 U.S. 85, 103 S.Ct.

ES FT Rae PD RIGOR oe vavecca decercveceseets

iv

TABLE OF AUTHORITIES —- Continued

Page

STATUTES

The Employee Retirement Income Security Act of

1974 (“ERISA”), 29 U.S.C. §§ 1001-1461...... 1, 9, 10

The Maine Workers’ Compensation Act of 1992

(“MWCA”), 39-A M.R.S.A. §§ 101-909 (Supp.

RPO a5. + abs FAs tiv de oT gd Fe CE Coke omen banka ene’ passim

D.C. Code Ann. § 36-307(a-1)(1) (1992)..........000. 11

Rat. See Ann. GSTS AMs © is av eek Meecbogebseas 3

BRIEF IN OPPOSITION

The Respondent, Theresa Ciampi, respectfully

requests that this Court deny the Petition for Writ of

Certiorari seeking review of the opinion of the Maine

Supreme Judicial Court in this case.

¢

OPINIONS BELOW

The opinion of the Maine Supreme Judicial Court

sought to be reviewed by the Petitioner is correctly set

forth in Petitioner’s Appendix.

¢

STATUTORY PROVISIONS INVOLVED

Petitioner correctly observes that this case involves

both the Employee Retirement Income Security Act of

1974 (“ERISA”), 29 U.S.C. §§ 1001-1461, and provisions of

the Maine Workers’ Compensation Act of 1992

(“MWCA”), 39-A M.R.S.A. §§ 101-909 (Supp. 1996). Peti-

tioner correctly sets forth the relevant provisions of both

statutes.

STATEMENT OF THE CASE

On January 30, 1993, the Respondent, Theresa

Ciampi, suffered a compensable injury while working for

the Petitioner, Hannaford Brothers. At the time of her

injury Respondent’s average weekly wage was $389.30

without the inclusion of the value of her fringe benefits.

As part of her compensation package, Petitioner provided

Respondent with medical and dental health insurance,

disability and group life insurance, a defined benefit

retirement plan and a 401(k) plan.

Pursuant to 39-A M.R.S.A. § 102(4)(H), Respondent

petitioned the Maine Workers’ Compensation Board

(hereinafter “Board”) to include the value of her fringe

benefits in its calculation of her average weekly wage.

The Petitioner opposed the petition on the ground that

ERISA preempted § 102(4)(H). The Board ordered that the

value of the Respondent's fringe benefits be included in

the calculation of her average weekly wage but did not

address the issue of ERISA preemption finding that such

a determination was beyond its jurisdiction. The Peti-

tioner, having preserved the issue of ERISA preemption,

sought review of the Board’s order with the Maine

Supreme Judicial Court.

The Supreme Judicial Court granted Petitioner

review of the Board’s order and held that 39-A M.R.S.A.

§ 102(4)(H) is not preempted by ERISA because it has

only a “tenuous, remote or peripheral” connection with

ERISA covered benefit plans. Ciampi v. Hannaford Bros.

Co., 681 A.2d 4 (Me. 1996).

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REASONS FOR DENYING THE WRIT

The decision below in no way sanctions any attempt

by the State of Maine either to evade this Court’s holding

in District of Columbia v. Greater Washington Board of Trade,

506 U.S. 125, 113 S.Ct. 580, 121 L.Ed.2d 513 (1992) or to

directly impact on ERISA plans by encouraging

employers to continue paying fringe benefits during the

ROE NRE AOS TN TT Le TOC Len nan a mmr |

course of an employee’s disability. On the contrary, the

Maine Supreme Judicial Court found, after a search of the

legislative record surrounding the enactment of the chal-

lenged provision, that the Maine Legislature had mani-

fested no intent to directly impact ERISA plans. The

Maine Court also properly concluded, as will be set forth

more fully below, that the workers’ compensation provi-

sion in question was not preempted by ERISA in light of

this Court’s holdings in Greater Washington and New York

State Conf. of Blue Cross & Blue Shield Plans v. Travelers Ins.

CO og cece WD e cent map LAD DAL. 1671, 1674-75, 131 L.Ed.2d

695 (1995).

As a further basis for concluding that the Maine

legislature had not intended to directly impact ERISA

plans by encouraging employers to continue fringe bene-

fits during the course of an injured worker’s disability,

the Court pointed out that § 102(4)(H) does not require

that employers in all instances include the value of fringe

benefits in calculating an injured worker’s average

weekly wage. Under the Maine approach, the value of

fringe benefits is only included in those instances in

which an injured worker’s average weekly wage is less

than two-thirds of the average weekly wage in the state.

This unique feature of the Maine statute implicates ERISA

to a lesser degree than broadez statutes enacted in other

states which have nevertheless withstood ERISA chal-

lenges identical to those advanced here by Petitioner. See

e.g. Kan. Stat. Ann. 44-511(a)(2)(E). Those broader statutes

have required that the value of discontinued fringe bene-

fits be included in all instances when determining an

injured worker’s average weekly wage for the purposes

of arriving at a statutory compensation rate, not just

those instances when an injured worker’s average weekly

wage failed to exceed a statutory floor.

Petitioner has presented no evidence to this Court of

the existence of any intent by the Maine legislature to

circumvent this Court’s holding in Greater Washington.

Therefore, even assuming, for the sake of argument only,

the accuracy of Petitioner’s assertions of “attempts” by

other state legislatures around the nation to “evade” the

Federal scheme that is at the heart of ERISA, or this

Court’s holding in Greater Washington, this case would

not, in any event, present an opportunity to grapple with

that precise issue.

Finally, despite the identification of “fringe benefit”

provisions in other jurisdictions similar to the provision

enacted in Maine, at least one of which dates back to 1985

(Petition for Cert. at 10), Petitioner has failed to cite a

single case to this Court in which any tribunal in the

identified jurisdictions has found such a provision to be

preempted by ERISA.

I. THE DECISION BELOW IS CONSISTENT WITH

THE CONGRESSIONAL INTENT UNDERLYING

ERISA AND POSES NO THREAT TO FEDERAL

REGULATORY UNIFORMITY.

ERISA is intended to prevent states and their politi-

cal subdivisions from taking actions that directly or indi-

rectly regulate ERISA-covered employee benefit plans.

The broad preemptive language utilized by Congress was

designed to ensure that a uniform body of law would be

applied to ERISA-covered employee benefit plans in

order to minimize the administrative and financial bur-

den of complying with conflicting directives among states

or between states and the Federal government. Ingersoll-

Rand Co. v. Perry McClendon, 498 U.S. 133, 111 S.Ct. 478,

112 L.Ed.2d 474 (1990).

Courts have consistently recognized, however, that

“ERISA’s preemptive reach, although broad, is not unlim-

ited.” Raymond v. Mobil Oil Corp., 983 F.2d 1528, 1538 n.14

(10th Cir. 1993), cert. denied, 510 U.S. 822, 114 S.Ct. 81, 126

L.Ed.2d 49. Moreover, “ ‘a preemption provision

designed to prevent state interference with Federal con-

trol of ERISA plans does not require the creation of a

fully insulated legal world that excludes these plans from

regulation of any purely local transaction...‘ ERISA was

not meant to consume everything in its path.” Hook v.

Morrison Milling Co., 38 F.3d 776, 786 (5th Cir. 1994).

Congress provided an even more specific bar to

unchecked ERISA preemption by expressly exempting

“state workers’ compensation schemes from ERISA’s pur-

view, leaving intact the states’ traditional regulation and

oversight of this specialized system of insurance.” Com-

bined Management, Inc. v. Superintendent of the Bureau of

Ins. of State of Me., 22 F.3d 1, 4 (1st Cir. 1994), cert. denied,

115 S.Ct. 350, 130 L.Ed.2d 306.

The challenged provision is a part of the Maine

Workers’ Compensation Act and imposes no legal or

regulatory burden on ERISA-covered employee benefit

plans. Petitioner nevertheless contends that review of the

decision below, and ultimately § 102(4)(H) of the Maine

Workers’ Compensation Act, is necessary because “the

‘value of benefits’ approach is acquiring a momentum

that poses a present, nationwide threat to the uniform

regulation of ERISA benefits mandated by Congress.”

(Petition for Cert. at 10).

There is nothing in the challenged provision that

runs afoul of the regulatory uniformity intended by Con-

gress when enacting ERISA. At most, Petitioners have

alleged, although not persuasively demonstrated, possi-

ble economic effects resulting from an employer’s being

required to include the value of an injured worker’s

discontinued fringe benefits for purposes of calculating

the average weekly wage upon which the workers’ com-

pensation benefit is to be based. Petitioner provides as an

example the hypothetical and extra-record case of an

employer being “effectively precluded” from requiring an

employee who is a COBRA beneficiary to pay the full cost

of his or her coverage. (Petition for Cert. at 12). Petitioner

argues that because the value of an employee’s COBRA

coverage may ultimately be reflected in an increased

average weekly wage, it is effectively precluded from

collecting the employee’s contribution to the COBRA

plan. What Petitioner ignores is that it at all times retains

the ultimate discretion as to whether to provide any

benefits in the first place. COBRA is not relevant and

could not come into play absent an existing employee

benefit plan that was voluntarily offered by an employer.

Furthermore, there is no practical reason that an

employer, under the scenario presented in the Peti-

tioner’s hypothetical, could not simply change the mix of

benefits to wages it supplied to an employee, or of one

type of benefit to another type, to account for any per-

ceived COBRA “shortfall.” These are economic decisions

that are best made by Petition-r and are no different than

other economic decisions it must make as an employer in

light of the various existing state and federal regulatory

regimes. State and federal regulations with respect to

taxation presumably also have an impact upon ERISA

plans and yet Petitioner would face a difficult task in

attempting to argue that tax codes are consequently pre-

empted by ERISA.

Moreover, Petitioner’s contentions that the proper

exercise of state authority may pose a threat to “Federal

regulatory uniformity” was firmly rejected by the Third

Circuit in Keystone Chapter Assoc. Builders v. Foley, 37 F.3d

945 (3rd Cir. 1994), cert. denied, 115 S.Ct. 1393 (1995).

Keystone Chapter addressed the Pennsylvania Prevailing

Wage Act and found that it was not preempted even

though some of the benefits included in the prevailing

wage calculation could include ERISA plan benefits. Not-

ing that wage laws traditionally fall within the sphere of

the state’s police power, the Keystone court stated:

ERISA’s preemption clause aims “to ensure ben-

efit plans will be governed by only a single set

of regulations,” not to bestow on employers a

uniform regulatory and economic environment

for all their activities across the country. Because

states enact their own wage and non-ERISA

benefits regulations . . . employers must adjust

their operations according to locale. This admin-

istrative and financial burden arises from the

“patchwork scheme” of our federal system, a

system whose “separate spheres of govern-

mental authority” were not preempted by

ERISA.

Id. at 960 (internal citations omitted).

As Keystone makes clear, the operation of dissimilar

workers’ compensation laws throughout the nation is no

greater threat to Federal regulatory uniformity than the

operation of dissimilar wage laws. In both areas of legis-

lation, states have been afforded wide discretion. Ray-

mond v. Mobil Oil Corp., 983 F.2d at 1538 n.14. The

Raymond court instructed that:

Laws that have been ruled preempted are those

that provide an alternative cause of action to

employees to collect benefits protected by

ERISA, refer specifically to ERISA plans and

apply solely to them, or interfere with the calcu-

lation of benefits owed to an employee. Those

that have not been preempted are laws of gen-

eral application — often traditional exercises of

state power or regulatory authority —- whose

affect on ERISA plans is incidental.

ee:

Thus, to the extent that 39-A M.R.S.A. § 102(4)(H)

participates in a nationwide “trend”, that trend consists

only of permissible state legislation within the appropri-

ate ambit of state power. Furthermore, the challenged

Maine provision does not refer specifically to ERISA

plans, it does not apply solely to ERISA plans and it does

not in any way interfere with the calculation of benefits

owed to an employee. The calculation of an injured

worker’s average weekly wage is a traditional exercise of

state power. See Combined Mgt., 22 F.3d at 4. That exercise

has only an incidental impact upon an ERISA plan

because it does not mandate an employer or the adminis-

trator of a plan to do anything at all. See Lawrence Paper

Co. v. Gomez, 257 Kan. 932, 897 P.2d 134, 143 (1995), cert.

denied, 116 S.Ct. 187, 133 L.Ed.2d 124 (1995).

Notwithstanding the directive of § 102(4)(H), an

employer may decline to offer any or all employee wel-

fare benefit plans, it may terminate any or all of its

employee welfare benefit plans or it may alter the propor-

tional mix of benefits and wages in its overall benefit

package at its sole discretion. If the Petitioner fails to

exercise these options in an effort to maintain its compet-

itiveness in the labor marketplace that is its choice.

Il. THE COURT BELOW WAS CORRECT ON THE

MERITS BECAUSE IT UNDERSTOOD AND

PROPERLY APPLIED THIS COURT’S RECENT

HOLDINGS IN GREATER WASHINGTON BOARD

OF TRADE AND BLUE CROSS AND CORRECTLY

FOUND, IN LIGHT OF THOSE HOLDINGS, THAT

THE CHALLENGED MAINE LAW HAS ONLY A

“TENUOUS, REMOTE OR PERIPHERAL” RELA-

TIONSHIP TO ERISA PLANS THAT DOES NOT

WARRANT A FINDING OF ERISA PREEMPTION.

The ERISA preemption invoked by Petitioner and

properly applied by the Maine Supreme Judicial Court in

this case states:

Except as provided in subsection (b) of this sec-

tion, the provisions of this subchapter and sub-

chapter III of this chapter shall supersede any

and all State laws insofar as they may now or

hereafter relate to any employee benefit plan

described in section 1003(a) of this title and now

exempt under section 1003(b) of this title.

29 U.S.C. § 1144(a).

10

Employee benefit plans described in section 1003(a) and

subject to ERISA coverage are employee welfare benefit

plans and employee pension benefit plans.

The test for determining whether a state law or regu-

lation “relates to” an ERISA benefit plan is whether “in

the normal sense of the phrase . . . it has a connection

with or reference to such a plan.” Shaw v. Delta Air Lines,

Inc., 463 U.S. 85, 97, 103 S.Ct. 2890, 2900, 77 L.Ed.2d 490

(1983).

Among the employee benefit plans exempted from

ERISA coverage are those “maintained solely for the pur-

pose of complying with applicable workmen’s compensa-

tion laws or unemployment compensation or disability

laws.” Greater Washington, 506 U.S. at 127.

The Petitioner argues that the decision below ren-

dered by the Supreme Judicial Court of Maine is inconsis-

tent with this Court’s opinion in Greater Washington. The

District of Columbia statute found to be preempted under

ERISA by the Greater Washington Court, however, is com-

pletely distinguishable from the Maine provision that is

under consideration here. The District of Columbia stat-

ute preempted by Greater Washington required employers

who furnished health insurance coverage for their

employees to continue to furnish equivalent insurance to

injured employees receiving workers’ compensation ben-

efits. It stated:

Any employer who provides health insurance

coverage for an employee shall provide health

insurance coverage equivalent to the existing

11

health insurance coverage of the employee

while the employee receives or is eligible to

receive workers’ compensation benefits under

this chapter.

D.C. Code Ann. § 36-307(a-1)(1)(1992).

The Maine Supreme Judicial Court rightly observed

that the District of Columbia statute “compelled

employers to provide an ERISA type benefit for

employees receiving workers’ compensation benefits.”

(Petitioner’s App. at 6). In effect, an employer within the

District of Columbia who established an ERISA-covered

health insurance plan was not free to terminate that plan

and subsequently provide no equivalent health insurance

plan or coverage.

The Maine Supreme Judicial Court properly con-

trasted the Maine provision at issue with the preempted

District of Columbia statute. The Maine provision con-

tains no employer mandate with respect to its offering,

operation, administration or termination of an ERISA

plan, as had the statute under consideration in Greater

Washington. The Maine Supreme Judicial Court concluded

that the Maine provision “has only an indirect impact on

ERISA-regulated plans.” (Petitioner’s App. at 6). The

Court, citing Greater Washington, 506 U.S. at 130 n. 1, 113

S.Ct. at 583 n. 1, concluded that any connection between

the Maine provision permitting the inclusion of fringe

benefits provided under an ERISA plan for the purpose of

calculating an employee’s workers’ compensation rate,

under traditional state laws of workers’ compensation,

and the ERISA plan itself was “tenuous, remote and

peripheral.” (Petitioner’s App. at 11).

12

The Maine Court buttressed its conclusion by

responding briefly to Petitioner’s economic arguments.

Petitioner has continually argued that, “in a real eco-

nomic sense,” requiring employers to pay the value of a

benefit is no different than requiring the furnishing of an

equivalent benefit. (Petition for Cert. at 12). Citing this

Court’s holding in New York State Conf. of Blue Cross, ___

U.S. ___, __, 115 S.Ct. 1671, 1679 (1995), the Maine Court

stated:

“ ... ERISA does not shield plan administrators

from any and all possible economic influences

that may arise from state laws or regulations.

Many traditional areas of state regulation, such

as the regulation of workplace conditions or the

formulation of quality standards for hospital

services, can affect the cost of an ERISA plan but

are not superseded by ERISA because they have

only an indirect effect on plan administration.”

(Petitioner’s App. at 7).

Simply put, the purported economic impact of a state

law or regulation upon an ERISA plan is of no legal

consequence for purposes of ERISA preemption analysis.

Furthermore, Respondent submits that, in any event, the

issue of the future economic impact of the Maine provi-

sion upon Petitioner is so speculative that, even were it

legally cognizable, it would not be sufficiently developed

by Petitioner to be ripe for review by this Court.

Finally, although not specifically addressed by the

Maine Supreme Judicial Court in the decision below,

Respondent submits that there is a clear difference

between state laws and regulations that may arguably

“relate to” ERISA employee benefits plans and those that

siceetaniaeanaiaieiiaiiiiieaiiaeamaeiitel

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13

relate more generically and generally to employee bene-

fits. This distinction was first identified in Fort Halifax

Packing Co. v. Coyne, 482 U.S. 1, 107 S.Ct. 2211, 96 L.Ed.2d

1 (1987), and reaffirmed in Ingersoll-Rand Co. The distinc-

tion was most recently applied by the Tenth Circuit in

Guidry v. Sheet Metal Workers Nat. Pension Fund, 39 F.3d

1078 (10th Cir. 1994).

In Guidry, a Colorado statute exempting 75 percent of

disposable earnings from garnishment included pension

or retirement benefits within its definition of “disposable

earnings.” The Guidry court, while acknowledging that

the Colorado law did “refer generally to pension bene-

fits ...,” went on to point out that it did “not refer to

ERISA benefits specifically nor [did] it refer to ERISA

plans.” Id. at 1085. The distinction between ERISA

employee benefits and ERISA employee benefit plans was

also explained:

As the Supreme Court has pointed out,

“ERISA’s preemption provision does not refer to

state laws relating to ‘employee benefits,’ but to

state laws relating to ‘employee benefits plans.”

Because Colorado law here refers to benefits

rather than plans, “the language of the ERISA

presents a formidable obstacle to [preemption].”

Id. (internal citations omitted).

Just as was the case with the Colorado law under

discussion in Guidry, § 102(4)(H) of the Maine Workers’

Compensation Act makes no mention of “employee bene-

fit plans.” It refers very generally to “fringe or other

benefits.” It is at least arguable that this reference to

“fringe or other benefits” does not refer to ERISA bene-

fits. There can be no doubt, however, that there is no

14

mention whatsoever of an “employee benefit plan”

within the statutory text of § 102(4)(H). For this reason

alone, the Maine provision could not be preempted by

ERISA.

CONCLUSION

The decision of the Supreme Judicial Court, finding

no support in the legislative history for Petitioner’s alle-

gations that the Maine Legislature attempted to evade

this Court’s holdings in Greater Washington or Blue Cross

in the enactment of § 102(4)(H) of the Maine Workers’

Compensation Act, and further finding that the require-

ments of § 102(4)(H) did not trigger ERISA preemption

under the recent holdings of this Court or, for that matter,

of any court, was sound in all respects. The decision did

not subvert Congressional intent in enacting ERISA nor

did it conflict with Federal ERISA policy which has his-

torically recognized a broad exemption for the operation

of workers’ compensation systems through the traditional

exercise of state power.

Respectfully submitted,

James J. MacApAm

(Counsel of Record)

McTeacusg, Hicseet, MAcADAM,

Case, Watson & COHEN

Four Union Park

Topsham, Maine 04086

(207) 725-5581