City park ranger issued summons and complaint to dog owner for violating city ordinances requiring dogs to be leashed in city and specific city park.
Following dispositional hearing, the Portland District Court issued judgment fining dog owner $500. Dog owner appealed.
The Supreme Judicial Court held that city park ranger that issued citation to dog owner was at least a “de facto” officer under the de facto officer doctrine.
City park ranger that issued citation to dog owner for violating city ordinances requiring dogs to be leashed in city park was at least a “de facto” officer under the de facto officer doctrine and, thus, any uncertainty regarding the extent of park ranger’s legal authority to enforce the ordinances was not a defense to the citation; issue as to whether a park ranger appointed as a constable under the city code was required to satisfy the training requirements of law enforcement officer to enforce a city ordinance was unresolved.