NEPSK, Inc. v. Town of Houlton

          United States Court of Appeals
                        For the First Circuit


No. 01-1787

                   NEPSK, INC., D/B/A HOULTON CABLE,

                         Plaintiff, Appellant,

                                  v.

                           TOWN OF HOULTON,

                         Defendant, Appellee.


          APPEAL FROM THE UNITED STATES DISTRICT COURT

                       FOR THE DISTRICT OF MAINE

             [Hon. Gene Carter, U.S. District Judge]
       [Hon. Margaret J. Kravchuk, U.S. Magistrate Judge]


                                Before

              Torruella, Lynch, and Lipez, Circuit Judges.



     Roy T. Pierce, with whom Bruce C. Gerrity, and Preti,
Flaherty, Beliveau, Pachios & Haley, LLC were on brief, for
appellant.

     Patrick J. Scully, with whom Joseph J. Hahn, Kate S. Debevoise
and Bernstein, Shur, Sawyer & Nelson, P.A. were on brief, for
appellee.



                            March 13, 2002
               LIPEZ, Circuit Judge.       This suit arises out of a dispute

over a cable franchise for the Town of Houlton, Maine ("Town").                  In

early 1999, the Town decided not to renew the franchise held by

NEPSK, Inc., d/b/a Houlton Cable ("Houlton Cable").                    Instead, it

sought      competitive     proposals     for    a    new   cable   franchise,   and

eventually awarded the franchise to Houlton Cable's competitor,

Pine Tree Cablevision Associates ("Pine Tree"). Houlton Cable then

commenced this suit against the Town, alleging multiple violations

of the Cable Communications Policy Act of 1984, as amended by the

Cable Television Consumer Protection and Competition Act of 1992
and the Telecommunications Act of 1996 (codified in pertinent part
at 47 U.S.C. §§ 521-573) (the "Act").                 The district court granted

the Town's motion for judgment on the pleadings as to two counts of
the complaint, based on Houlton Cable's failure to respond to the
motion as required by District of Maine Local Rule 7(b).                     Several

months later, the court entered summary judgment for the Town on
the remaining count of the complaint.                   Houlton Cable challenges
both decisions.        We affirm.

                                          I.

               On   April   23,   1984,    the       Town   entered   into   a cable

franchise agreement with Houlton Cable's predecessor, Houlton CATV,

Inc.1       The franchise ran for a period of 15 years, and was set to

expire in April of 1999.          Under federal law, 47 U.S.C. § 546(a)-

        1
       With the exception of certain services not relevant here, "a
cable operator may not provide cable service without a franchise."
47 U.S.C. § 541(b).

                                          -2-
(g),   Houlton    Cable    was       entitled    to    initiate      formal   renewal

procedures by submitting a written request to the Town between

April and October, 1996.             If neither Houlton Cable nor the Town
took action within that six-month window, the renewal process would

be governed by the informal procedures set out in § 546(h).

           Houlton Cable submitted a renewal proposal in November,
1997, well      after    the    expiration      of    the    six-month     period   for

initiation of formal procedures. For several months, the Town took

no action on the proposal.               Then, in April of 1998, the Town

Council voted to "invite new applications for the Houlton Cable

franchise."       Consistent      with    the    informal      renewal     procedures

prescribed by § 546(h), the Town scheduled a public hearing to

address the cable franchise issue.                   Following that hearing, in
February of 2000, the Town Council decided not to renew Houlton

Cable's   franchise      and    to    solicit    bids       from   other   providers.

Minutes from the public hearing and the Town Council's subsequent
meeting indicate that Houlton Cable's refusal to provide high-speed

Internet access to its subscribers was a major factor in the Town's

decision to reject the renewal proposal.

           On    March    31,    2000,    the    Town       issued   a   Request    for

Proposals ("RFP") soliciting proposals for a new, ten-year cable

franchise.      As the RFP made clear, the Town did not believe it

could support more than one franchise.                       Although it had not

undertaken any detailed analysis of the issue, the Town was aware

that no municipality in Maine -- including those much larger than

Houlton -- was served by more than one cable company. Accordingly,


                                         -3-
the Town explained in the RFP that it planned to award only one

franchise:

            The Town of Houlton recognizes that it cannot
            award an exclusive cable television franchise
            to any applicant. Nevertheless, the Town also
            recognizes that the Town of Houlton can only
            feasibly   support   one   cable   television
            franchise at one time. Accordingly, the Town
            intends to award only one cable television
            franchise during the next ten year period,
            which will be the franchise as a result of
            this RFP process.

             The Town received proposals from two parties, Houlton

Cable and Pine Tree.       After considering both proposals, the Town

determined that Pine Tree's "most closely [met] the needs of the

Town as determined by public surveys and [the earlier] public
hearing."     At a meeting in May, 2000, the Town Council voted to

reject Houlton Cable's proposal, and to pursue negotiations with

Pine Tree.
             Houlton Cable then initiated this suit against the Town.

Count I of its complaint alleged that the Town violated the Act by

failing to comply with the formal renewal procedures set forth in

§ 546(a)-(g).     Count II alleged that the Town had conditioned the

renewal of Houlton Cable's franchise on Houlton Cable's willingness

to provide high speed internet service to its subscribers.         Such a

demand,      Houlton     Cable     maintained,    violated    47   U.S.C.

§   541(b)(3)(D),      which   prohibits   franchising   authorities   from

requiring cable operators to provide certain "telecommunication

service[s]" as a condition of a franchise award, and 47 U.S.C.

§ 544(e), which states that "[n]o State or franchising authority

may prohibit, condition, or restrict a cable system's use of any

                                     -4-
type of . . . transmission technology." Finally, Count III alleged

that the     Town    unreasonably     refused    to    award      Houlton    Cable   a

"second" franchise, in violation of 47 U.S.C. § 541(a)(1).
             After answering the complaint, the Town moved under Fed.

R. Civ. P. 12(c) for judgment on the pleadings as to Counts I and

II.    With respect to Count I, the Town argued that, since neither
Houlton Cable nor the Town had initiated formal renewal procedures

during the six-month window, the renewal process properly was

governed by the informal procedures authorized by § 456(h).                          In

response to Count II, the Town contended that the Act did not apply

retroactively       to   invalidate    the   terms     of   the    1984     Franchise

Agreement, which provided that the decision as to renewal was

committed to the Town's discretion, and would be based in part on
"the development of cable services."             In the alternative, the Town

argued     that      high-speed       internet       access       is   neither        a

"telecommunication service" nor a "transmission technology," and
therefore is not governed by §§ 541(b)(3)(D)(a) and 544(e) of the

Act.

             Pursuant to Local Rule 7(b) of the District of Maine,

Houlton Cable was obligated to respond to the Town's motion within

ten days.2    Houlton Cable did not so respond, and, accordingly, was

deemed to have consented to the motion.               Thus, on December 7, 2000

-- one day after the ten-day period had expired -- the district




       2
       Rule 7(b) has since been amended to permit response "within
twenty-one (21) days after the filing of a motion."

                                       -5-
court entered judgment for the Town on Counts I and II "per Local

Rule 7(b)."
           Houlton Cable filed a motion under Fed. R. Civ. P. 59(e),
asking the court to reconsider and vacate its December 7 judgment.

It argued that the district court could not enter judgment on the
pleadings without first satisfying itself that the Town was in fact
entitled to judgment as a matter of law.          The court granted the
motion for reconsideration, but reaffirmed its initial judgment.
Rule 12(c), the court noted, does not prescribe any particular
standard of decision; therefore, it does not prohibit the entry of

judgment on the basis of noncompliance with a local waiver rule,

without consideration of the merits of the motion.               Given the

absence of a direct conflict between Federal Rule 12(c) and Local
Rule 7(b), the court concluded that it was entitled to enforce its

local rule strictly.

           The Town then moved for summary judgment on Count III of
Houlton   Cable's   complaint,    arguing    that     the   provisions   of

§   541(a)(1)   governing   applications    for   a   second,   competitive

franchise did not apply to the Town's choice to award an initial
franchise to one provider rather than another.          The court3 agreed,

and entered judgment for the Town on Count III.             Houlton Cable

filed a timely notice of appeal, challenging the district court's



      3
       After the district court dismissed Counts I and II of
Houlton Cable's complaint, the parties consented to further
proceedings in the case before a magistrate judge. See Fed. R.
Civ. P. 73(b). For the sake of simplicity, we refer to both the
magistrate judge and the district court judge as the "district
court" or the "court."

                                  -6-
December 7 grant of judgment on the pleadings as to Counts I and

II, its refusal to rescind that judgment under Rule 59(e), and its
grant of summary judgment on Count III.

                                II.

          We turn, first, to the district court's decisions with
respect to Counts I and II.     In granting the Town's motion for

judgment on the pleadings, the court relied on District of Maine

Local Rule 7(b), which then provided:
          Unless within ten (10) days after the filing
          of a motion the opposing party files written
          objection thereto, incorporating a memorandum
          of law, the opposing party shall be deemed to
          have waived objection.
Houlton Cable conceded that it did not comply with that rule, and
that its failure to file a timely response did not constitute

"excusable neglect," permitting reconsideration under Fed. R. Civ.

P. 60(b)(1).   Thus, Houlton Cable sought relief under Fed. R. Civ.
P. 59(e) on the ground that the district court's judgment was based

on an error of law.   See Acevedo-Villalobos v. Hernandez, 22 F.3d

384, 390 (1st Cir. 1994) (explaining that Rule 59(e) is the proper
vehicle for a party seeking to overturn a judgment on the basis of

alleged legal errors).    Maintaining that Rule 12(c) requires a
decision on the merits, it argued that the district court erred as

a matter of law when it granted the Town's motion for judgment on
the pleadings solely on the basis of a local "deemed waiver" rule
like Rule 7(b).

          Houlton Cable renews that argument on appeal.   We review
the district court's initial application of its local rule for


                                -7-
abuse of discretion.   CMM Cable Rep, Inc. v. Ocean Coast Props.,

Inc., 97 F.3d 1504, 1528 (1st Cir. 1996).            We apply the same
standard to the district court's denial of a Rule 59(e) motion to
alter or amend the judgment.    See Williams v. Poulos, 11 F.3d 271,

289 (1st Cir. 1993).   However, the court's interpretation of Rule
12(c) of the Federal Rules of Civil Procedure presents a legal
question, which we review de novo.         See Sec. & Exch. Comm'n v.
Sargent, 229 F.3d 68, 79 (1st Cir. 2000).

          Local Rule 7(b) and its predecessor, District of Maine
Local Rule 19(c), have been in existence for almost 20 years.4

Courts in the District of Maine routinely apply such rules in

situations where the opposing party fails to file an objection to

a motion, regardless of whether the motion is dispositive.           See,

e.g., Cardente v. Fleet Bank, 796 F. Supp. 603 (D. Me. 1992) (Rule

12(b)(6) motion to dismiss); United Transp. Union v. Me. Cent. R.R.

Co., 107 F.R.D. 383, 383-84 (D. Me. 1985) (motion to dismiss for
lack of personal jurisdiction and improper venue); Gideon v. Adm'r,

United States Small Bus. Admin., 102 F.R.D. 604 (D. Me. 1984)

(motion to dismiss for lack of subject matter jurisdiction); see
also Desjardins v. Van Buren Cmty. Hosp., 969 F.2d 1280 (1st Cir.

1992) (affirming,   against    First    Amendment   challenge,   district

court's order requiring defendant to make a public apology, on

ground that district court properly relied on Local Rule 19(c) to
find that defendant waived objection to plaintiff's motion to

     4
      Local Rule 19(c) provided: "Unless within 10 days after the
filing of a motion the opposing party files a written objection
thereto, he shall be deemed to have waived objection."

                                  -8-
compel apology).    Other districts throughout the country have

adopted similar rules5 to "ensure the orderly, efficient, and
expeditious management of the extensive motion practice" of the
district courts.   McDermott v. Lehman, 594 F. Supp. 1315, 1319 (D.

Me. 1984).
          We have recognized that "[d]istrict courts enjoy broad
latitude" in adopting and administering such local rules. Air Line

Pilots Ass'n v. Precision Valley Aviation, Inc., 26 F.3d 220, 224
(1st Cir. 1994); see also, e.g., Ramsdell v. Bowles, 64 F.3d 5, 7
(1st Cir. 1995) (acknowledging the district court's "great leeway

in the application and enforcement of its local rules").        In

exercising that discretion, district courts may, where appropriate,

"demand adherence to specific mandates contained in the rules."
Air Line Pilots Ass'n, 26 F.3d at 224.    For example, in Corey v.

Mast Road Grain & Bldg. Materials Co., Inc., 738 F.2d 11 (1st Cir.

1984) (per curiam), the defendants moved for dismissal under Fed.

     5
       See, e.g., D. Ariz. LR 1.10(i) ("If a motion does not
conform in all substantial respects with the requirements of this
Rule, or if the opposing party does not serve and file the required
answering memoranda, . . . such non-compliance may be deemed a
consent to the denial or granting of the motion and the Court may
dispose of the motion summarily."); C.D. Ill. LR 7.1(B)(1) ("If no
response memorandum is filed within [14 days after service of a
motion], the presiding judge will presume there is no opposition
and may rule on the motion without further notice to the
parties."); N.D. Ind. LR 7.1(a) ("Failure to file a response
[within 15 days after service of a motion] may subject the motion
to summary ruling."); D.N.H. LR 7.1(b) ("The court shall deem
waived any objection not filed in accordance [within 10 days from
the date the motion was filed]."); D.N.M. LR-Civ. 7.5(b) ("Failure
to serve (or file, if required by these rules) a response in
opposition to any motion constitutes consent to grant the
motion."); D. Nev. LR-Civ. 7-2(d) ("The failure of an opposing
party to file points and authorities in response to any motion
shall constitute a consent to the granting of the motion.").

                                -9-
R. Civ. P. 12(b) for lack of personal jurisdiction.         The district

court granted the motion on the basis of the plaintiff's failure to
file a timely response, as required by Local Rule 12 of the
District of Massachusetts.     It later denied the plaintiff's Rule

60(b)(1) motion for relief from the judgment. We affirmed, stating
that "[t]he district court was entitled to insist upon compliance
with its local rule in these circumstances."       Id. at 12 (citing In

re Harbour House Operating Corp., 724 F.2d 1, 2-3 (1st Cir. 1983)
(strictly applying Rule 3(b) of the First Circuit Rules governing
bankruptcy appeals)).    Given plaintiff's failure to establish that

her tardiness was caused by excusable neglect, we concluded that

"the   court   could    properly    decline   to   excuse    plaintiff's

noncompliance with the local rule."           Id.; accord Stanciel v.

Gramley, 267 F.3d 575, 579 (7th Cir. 2001) (affirming district

court's grant of motion to dismiss on the basis of noncompliance

with local rule requiring response within 14 days); Tobel v. City

of Hammond, 94 F.3d 360, 361-62 (7th Cir. 1996) ("Plaintiffs'

lawyers admit that they were not aware of the Local Rule.        This is

the end of the matter because the district court clearly has
authority to enforce strictly its Local Rules, even if a default

results."); Ghazali v. Moran, 46 F.3d 52, 53 (9th Cir. 1995)

("Failure to follow a district court's local rules is a proper

ground for dismissal.").
          We reached a similar result in United States v. Proceeds

of Sale of 3,888 Pounds of Atlantic Sea Scallops, 857 F.2d 46 (1st

Cir. 1988). There, the government had filed a forfeiture action in


                                   -10-
Rhode Island district court, hoping to obtain title to the value of

certain sea scallops it had seized.        Roughly one month later, the
defendant filed a combined "answer and claim," which the government
moved to strike as untimely. The district court granted the motion

to strike, based on the defendant's failure to respond within ten
days as required by Local Rule 12(a)(2). The government then moved
for a default judgment on the ground that the defendant's claim and
answer had been stricken.     The district court granted that motion
as well, reaffirming its decision on the defendant's Rule 60(b)
motion for reconsideration.

           Again, we affirmed.    As in Corey, we concluded that the

district court did not abuse its discretion in refusing to grant

favorable reconsideration under Rule 60(b)(1) in the absence of a
showing   of   excusable   neglect.      See    id.   at   49    (finding   that

defendant's alleged reliance on erroneous advice from local counsel

did not excuse untimely filings).         We continued:          "We also agree
with the district court that a default judgment may stand even

where there has been no showing of substantial prejudice to the

party benefitting from the default.            A district court simply may

insist upon compliance with its local rules."              Id.

           As our holdings in Corey and Sea Scallops make clear, it

is within the district court's discretion to dismiss an action

based on a party's unexcused failure to respond to a dispositive
motion when such response is required by local rule, at least when




                                  -11-
the   result   does   not   clearly    offend   equity.6   See   Pinto   v.

Universidad de Puerto Rico, 895 F.2d 18, 19 & n.1 (1st Cir. 1990)
("We do not agree with defendant that a court may, without notice,
take a failure to respond to a motion to dismiss as a default,

warranting dismissal irrespective of substantive merit. . . . To be
distinguished is where a court had ordered a memorandum, and, of
course, cases where a response was required by rule." (citing Sea

Scallops and Corey)).         It is equally clear, however, that a
district court cannot enforce its local rules in a way that
conflicts with the Federal Rules of Civil Procedure.         See Fed. R.

Civ. P. 83(a)(1); Jaroma v. Massey, 873 F.2d 17, 20 (1st Cir. 1989)

("Local district court rules cannot be construed in such a way as


      6
       We have cautioned that this discretion "is not unbridled."
United States v. Roberts, 978 F.2d 17, 20 (1st Cir. 1992).       In
Roberts, we held that the district court abused its discretion in
denying the government's motion to reconsider an order granting the
defendant's motion to suppress certain evidence as unopposed under
Maine's Local Rule 19(c) (the predecessor to Rule 7(b)). Unlike
Houlton Cable, the government in Roberts argued that its failure to
comply with the local rule was caused by excusable neglect. We
found that argument persuasive, and concluded that "the lower court
probably undervalued the worth of the [government's] explanation."
Id. at 22.    We also noted that "it would have helped" if the
district court had considered several other factors in deciding the
government's motion to reconsider. Id. at 21-22 (listing factors
such as the degree of tardiness, the nature of the case, and "the
effect of granting (or denying) the motion on the administration of
justice").
     This case does not require us to determine whether and how
Roberts might apply where, as here, the tardy party failed to offer
a "credible explanation of what [went] wrong." Id. at 25. Houlton
Cable does not argue that the district court erred by failing to
take into account equitable considerations like those we outlined
in Roberts. Instead, in both the district court and on appeal,
Houlton Cable has argued only that the court's strict application
of Local Rule 7(b) creates an impermissible conflict with Federal
Rule 12(c). As we explain below, the district court did not err in
rejecting that argument.

                                      -12-
to render them inconsistent with applicable provisions of the

Federal Rules of Civil Procedure.").
          As Houlton Cable points out, we have identified such a
conflict in the context of motions for summary judgment filed under

Fed. R. Civ. P. 56.    Rule 56(e) specifies that, if such a motion
is unopposed, the district court may grant summary judgment "if
appropriate."   "Under this provision it is clear that '[w]here the
evidentiary matter in support of the motion does not establish the
absence of a genuine issue, summary judgment must be denied even if
no opposing evidentiary matter is presented.'" Jaroma, 873 F.2d at

20 (quoting Stepanischen v. Merchants Despatch Transp. Corp., 722

F.2d 922, 929 (1st Cir. 1983)).    Thus, a district court may not

automatically grant a motion for summary judgment simply because
the opposing party failed to comply with a local rule requiring a

response within a certain number of days.   Rather, the court must

determine whether summary judgment is "appropriate," which means
that it must assure itself that the moving party's submission shows

that "there is no genuine issue as to any material fact and that

the moving party is entitled to judgment as a matter of law."   Fed.

R. Civ. P. 56(c); see also Advisory Committee Note to Rule 56

("Where the evidentiary matter in support of the motion does not

establish the absence of a genuine issue, summary judgment must be

denied even if no opposing evidentiary matter is presented.").
          Given the potential tension between Rule 56(e) and local

rules such as the District of Maine's Rule 7(b), we have recognized

the need to interpret local waiver rules "so as to preserve [their]


                               -13-
scope and validity without running afoul of the requirements of

Rule 56."      Jaroma, 873 F.2d at 20.   To that end, in the summary
judgment context we read the "deemed waiver" provision of the local
rules to extend only to waiver of objection to the moving party's

factual assertions.     By failing to file the required response
within the time prescribed by the applicable local rule, the non-
moving party
            waives the right to controvert the facts
            asserted by the moving party in the motion for
            summary judgment and the supporting materials
            accompanying it.    The court will accept as
            true all material facts set forth by the
            moving party with appropriate record support.
            If those facts entitle the moving party to
            judgment as a matter of law, summary judgment
            will be granted.

Jaroma, 873 F.2d at 21 (emphasis added); see also McDermott, 594 F.

Supp. at 1321 (same).

            Houlton Cable argues that the district court's obligation

to address the merits of a motion for summary judgment should
extend as well to Rule 12(c) motions for judgment on the pleadings.

It emphasizes that a party seeking judgment on the pleadings under

Rule 12(c) will make precisely the same arguments as a party

seeking summary judgment under Rule 56; namely, that "no material

issue of fact remains to be resolved and that he is entitled to

judgment as a matter of law."    5A Charles Alan Wright & Arthur R.

Miller, Federal Practice & Procedure § 1368, at 518 (2d ed. 1990);

Lefebvre v. Comm'r, 830 F.2d 417, 419 (1st Cir. 1987) (per curiam)

(describing standard for Rule 12(c)).    The only difference is that

a Rule 12(c) motion must be filed at the close of pleadings, and


                                 -14-
must be based solely on the factual allegations in the complaint

and answer, whereas a motion for summary judgment may be filed at
any time, and may be supported by additional materials such as
affidavits, depositions, and the like.        Compare Fed. R. Civ. P.

12(c) with Fed. R. Civ. P. 56.          Such procedural differences,
Houlton   Cable   maintains,   should   not   obscure   the    fundamental
similarity between the substance of a Rule 12(c) motion on the one
hand, and a Rule 56 motion on the other.        Given that similarity,
Houlton Cable insists that the district court cannot rely on its
local rule to grant a Rule 12(c) motion, when it could not do the

same if the motion had been filed under Rule 56.

           Although that argument is not without force, it ignores

an important -- and, in our view, dispositive -- difference between
the two federal rules.   Unlike Rule 56, nothing in the text of Rule

12(c) compels the court to apply any particular standard when

deciding whether to grant or deny a motion for judgment on the
pleadings.   Rule 12(c) provides that, "[a]fter the pleadings are

closed but within such time as not to delay the trial, any party

may move for judgment on the pleadings."         As the district court
observed, the rule "poses no standard or regime by which the Court

shall decide the issues generated by the motion."             By contrast,

Rule 56(c) specifically states that summary judgment "shall" be

granted "if the pleadings, depositions, answers to interrogatories,
and admissions on file, together with the affidavits, if any, show

that there is no genuine issue as to any material fact and that the

moving party is entitled to a judgment as a matter of law."


                                 -15-
Moreover, Rule 56 explicitly addresses the possibility that the

non-moving party will not respond to the motion, and provides that
summary judgment may be entered in such circumstances only "if
appropriate."     Fed. R. Civ. P. 56(e).          Rule 12(c), on the other

hand, does not require the court to make any such determination
before granting the motion.
             Given Rule 12(c)'s silence on the subject, we cannot
conclude that the district court's strict enforcement of Local Rule
7(b) creates an impermissible conflict with federal Rule 12(c). As
the district court put it, "[t]here is simply no reason contained

in   [Rule   12(c)]   or   its   intendment   to    prevent   an   otherwise

appropriate and enforceable rule of default, i.e. Local Rule 7(b),

from operating on a motion under Rule 12(c) without consideration
by the court of its merits."          Accord Tobel, 94 F.3d at 362-63

(affirming grant of motion for judgment on the pleadings based on

opposing party's failure to respond as required by local rule);
Ghazali, 46 F.3d at 54 (reasoning that standards governing summary

judgment motions do not apply to motions to dismiss, and holding

that district court did not abuse its discretion in granting motion
to   dismiss    for   noncompliance   with    a    local   rule    specifying

requirements for response).       We agree, and hold that the district

court did not abuse its discretion in insisting on compliance with

its local rule and in rejecting Houlton Cable's assertion of legal
error under Rule 59(e).

                                    III.




                                    -16-
             We turn to Houlton Cable's claim that the district court

erred in granting summary judgment to the Town on Count III of the
complaint.     As noted, Count III asserted a claim for relief based
on an alleged violation of 47 U.S.C. § 541(a)(1), which provides:

             A   franchising   authority   may   award,   in
             accordance with the provisions of this
             subchapter, 1 or more franchises within its
             jurisdiction;   except   that   a   franchising
             authority may not grant an exclusive franchise
             and may not unreasonably refuse to award an
             additional   competitive    franchise.      Any
             applicant whose application for a second
             franchise has been denied by a final decision
             of the franchising authority may appeal such
             final decision pursuant to the provisions of
             section 555 of this title for failure to
             comply with this subsection.

Section 555, in turn, authorizes "[a]ny cable operator adversely

affected by any final determination made by a franchising authority
under section 541(a)(1)" to appeal that decision to the federal

district court in the district in which the cable system is

located.     47 U.S.C. § 555(a).
             As far as we can tell, the question whether § 541(a)(1)

creates a cause of action for a cable provider that lost out in a

competitive bidding process for a single franchise is one of first

impression.     By its terms, § 541(a)(1) governs only applications

for a "second" franchise. Thus, the parties agree that § 541(a)(1)

does   not   speak   to   the   Town's   decision   to   award    the   initial

franchise to Pine Tree instead of Houlton Cable.                 Houlton Cable
argues, however, that once the Town decided to award a franchise to

Pine Tree, it was obligated to determine whether it also should

award Houlton Cable an "additional competitive" franchise. Because


                                    -17-
the    Town   readily     admits      that    it    never   even   considered    that

question, Houlton Cable maintains that the outright denial of its
franchise proposal was "unreasonabl[e]" within the meaning of
§ 541(a)(1).

              The difficulty with that argument is that Houlton Cable
never submitted an application for a "second" franchise.                       Hence,
the Town never refused such an application, unreasonably or not.
The RFP made clear that the Town was soliciting bids for a single
franchise.      Houlton Cable's proposal -- submitted in response to
the RFP -- was, therefore, an application for that first, single

franchise.       Nowhere in its proposal did Houlton Cable indicate

that, if the Town decided to grant the initial franchise to Pine

Tree,    Houlton    Cable    wished      to    be    considered      for   a   second,
competitive franchise.

              Houlton Cable concedes as much.               However, it maintains

that such a desire can be assumed whenever two or more providers
submit applications for a single franchise.                    In Houlton Cable's

view, the losing co-applicant necessarily must be considered as an

applicant for a second franchise, whether or not it explicitly
asked for such treatment.             We disagree.      It is one thing to apply

for a single franchise; it is quite another to apply for a second,

competitive franchise.           The latter may be far less profitable and,

therefore, far less attractive. As a result, it cannot be presumed
that    an    applicant    for    a    first    franchise     also    wishes    to   be

considered for a second, competitive franchise.




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           Moreover, as the district court aptly observed, the

information a franchising authority -- and a reviewing court --
would consider in assessing an application for a second franchise
might be very different from the type of information needed to

weigh the strengths and weaknesses of competing applications for a
first   franchise.       The      choice     of    one     provider    over   another
implicates questions such as which provider offers the better
package of services, and at the best price.                      By contrast, the
decision whether to award a second franchise (once one has been
established)    raises      a    different      set   of   concerns:      Could   the

municipality's infrastructure support two cable grids? Would it be

technically feasible for a second provider to build its own system

over the existing one?             Cf. City of Los Angeles v. Preferred

Communications, Inc., 476 U.S. 488, 495 (1986) (noting that factors

such as "the present uses of the public utility poles and rights-

of-way and     how   [the       cable   operator]     proposes    to    install   and
maintain its facilities on them" were relevant to the question

whether the City violated the First Amendment by refusing to grant

more than one cable franchise).

           Of course, both sets of questions could be addressed at

once, in the initial selection process.                    But it does not follow

that they must be, or that the Town is obligated to raise the issue

of a second franchise sua sponte.                 Rather, if an applicant like
Houlton Cable wishes to be considered for a second franchise in the

event it is not chosen for the first, it must make that desire

explicit in its proposal.           Unless and until Houlton Cable submits


                                         -19-
-- and the Town refuses -- an actual "request" for a "second"

franchise, it has no cause for complaint under § 541(a)(1).          See I-
Star Communications Corp. v. City of East Cleveland, 885 F. Supp.
1035, 1042 (N.D. Ohio 1995) (dismissing § 541(a)(1) claim based on

plaintiff's   failure   to   allege   submission,   and   denial,    of   an
application   for   a   second   competitive   franchise);     cf.    City

Communications, Inc. v. City of Detroit, 685 F. Supp. 160, 162-63
(E.D. Mich. 1988) (holding that unsuccessful applicant for single
franchise could not bring First Amendment challenge to City's
decision to award only one franchise until it actually submitted an

application for a second franchise, accompanied by a feasibility

study, and such application was denied), aff'd on other grounds,

888 F.2d 1081 (6th Cir. 1989).

                                  IV.

          For the reasons set forth above, we affirm the judgment
of the district court on Counts I, II, and III.

          So ordered.




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