comprehensive framework (Massachusetts) · Go Syfert
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comprehensive framework in Massachusetts

23 Massachusetts opinions name it 4 courts 1976–2025 5 in the last five years

The cases below were cited by Massachusetts courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Sahin v. Sahingreen
mass · 2001 · cited in 12 Massachusetts opinions naming this issue, 2002–2025
2 sentences

2025See Sahin v. Sahin, 435 Mass. 396, 399-400 (2001) ("Rule 60 sets forth a comprehensive framework for obtaining relief from a final judgment or order").

2025"Rule 60 sets forth a comprehensive framework for obtaining relief from a final judgment or order, balancing the competing needs for finality and flexibility to be certain that justice is done in light of all the facts." Owens v. Mukendi, 448 Mass. 66, 71 (2006), quoting Sahin v. Sahin, 435 Mass. 396, 399-400 (2001).

1212
Owens v. Mukendigreen
mass · 2006 · cited in 2 Massachusetts opinions naming this issue, 2024–2025
2 sentences

2025"Rule 60 sets forth a comprehensive framework for obtaining relief from a final judgment or order, balancing the competing needs for finality and flexibility to be certain that justice is done in light of all the facts." Owens v. Mukendi, 448 Mass. 66, 71 (2006), quoting Sahin v. Sahin, 435 Mass. 396, 399-400 (2001).

2024"Rule 60 sets forth a comprehensive framework for obtaining relief from a final judgment or order, balancing the competing needs for finality and flexibility to be certain that justice is done in light of all the facts." Owens v. Mukendi, 448 Mass. 66, 71 (2006), 7 quoting Sahin v. Sahin, 435 Mass. 396, 399-400 (2001).

22
Putnam v. Putnamgreen
massappct · 1977 · cited in 2 Massachusetts opinions naming this issue, 1980–1990
2 sentences

1990An equitable division should not be ordered in a case where *342 the evidence introduced by the parties does not warrant findings comprehensive of those factors.” Putnam v. Putnam, 5 Mass. App. Ct. 10, 17 (1977). 4 Lest the provisions of the judgment ordering conveyances of the properties in question be misinterpreted as an equitable division, possibly precluding an equitable division in the future (see Maze v. Mihalovich, 1 Mass. App. Ct. 323, 324-326 [1979]; Davidson v. Davidson, 19 Mass. App. Ct. 364, 367-368 [1985]), the judgment should be clarified to state expressly that the conveyances

1980Her order encompasses “all substantial assets jointly owned and any separate property representing accretion during the marriage, [and is clearly] based on a comprehensive analysis of all major elements of contribution by the spouses during the marriage.” Putnam v. Putnam, 7 Mass. App. Ct. at 673 , quoting Putnam v. Put *732 nam, 5 Mass. App. Ct. 10, 17 (1977).

22
Chavoor v. Lewisgreen
mass · 1981 · cited in 1 Massachusetts opinions naming this issue, 2025–2025
1 sentence

2025As part of that framework, "[m]otions under rule 60 (b) (1), (2), and (3) must be brought at least within one year of the challenged order." Department of Revenue v. W.Z., 412 Mass. 718 , 721 n.4 (1992), citing Chavoor v. Lewis, 383 Mass. 801, 803 (1981).

11
Alliance to Protect Nantucket Sound, Inc. v. Energy Facilities Siting Boardgreen
mass · 2010 · cited in 1 Massachusetts opinions naming this issue, 2024–2024
1 sentence

2024See Alliance II, 457 Mass. at 678 n.27. [18] The petitioners argue that the board erred in concluding that the substation "requires an adjacent location" to the preexisting water dependent transmission line, see 310 Code Mass. Regs. § 9.02, because the term "requires" means "necessitates." According to the petitioners, the existence of alternate potential sites showed that it was not necessary for the substation to be located where Eversource proposed.

11
Labor Relations Commission v. Boston Teachers Uniongreen
mass · 1977 · cited in 1 Massachusetts opinions naming this issue, 2019–2019
1 sentence

2019Labor Relations Comm'n v. Boston Teachers Union, Local 66, 374 Mass. 79, 93 (1977).

11
Freitas v. Freitasgreen
massappct · 1988 · cited in 1 Massachusetts opinions naming this issue, 2016–2016
1 sentence

2016Subdivision (b)(6) of the rule is a catchall provision, applicable when subdivisions (b)(1) through (b)(5) do not apply, that allows relief from judgment for “any other reason justifying relief from the operation of the judgment.” See Parrell v. Keenan, 389 Mass. 809, 814 (1983); Freitas v. Freitas, 26 Mass. App. Ct. 196, 197 (1988).

11
Parrell v. Keenangreen
mass · 1983 · cited in 1 Massachusetts opinions naming this issue, 2016–2016
1 sentence

2016Subdivision (b)(6) of the rule is a catchall provision, applicable when subdivisions (b)(1) through (b)(5) do not apply, that allows relief from judgment for “any other reason justifying relief from the operation of the judgment.” See Parrell v. Keenan, 389 Mass. 809, 814 (1983); Freitas v. Freitas, 26 Mass. App. Ct. 196, 197 (1988).

11
Mt. Ivy Press, L.P. v. Defonsecagreen
massappct · 2014 · cited in 1 Massachusetts opinions naming this issue, 2015–2015
1 sentence

2015Ivy Press, L.P. v. Defonseca, 85 Mass. App. Ct. 241, 245 (2014), quoting Sahin v. Sahin, 435 Mass. 396, 399-400 (2001).

11
Boothroyd v. Zoning Board of Appealsgreen
mass · 2007 · cited in 1 Massachusetts opinions naming this issue, 2008–2008
1 sentence

2008Boothroyd v. Zoning Bd. of Appeals of Amherst, 449 Mass. 333, 340 (2007).

11
Scannell v. Ed. Ferreirinha & Irmao, Lda.green
mass · 1987 · cited in 1 Massachusetts opinions naming this issue, 2004–2004
1 sentence

2004The decision on a motion under this rule is committed to the sound discretion of the trial judge and will not be reversed on appeal absent a clear showing of abuse of discretion, Scannell v. Ed Ferreirinha & Irmao, Lda., 401 Mass. 155, 157-158 (1987), “that is, if it was a ruling that ‘no conscientious judge, acting intelligently, could honestly’ have made.” Maniscola v. Kenworthy, 2002 Mass. App. Div. 203, 204 , quoting Mazzoleni v. Cotton, 33 Mass. App. Ct. 147, 152-153 (1992), quoting Davis v. Boston Elev.

11
Mazzoleni v. Cottongreen
massappct · 1992 · cited in 1 Massachusetts opinions naming this issue, 2004–2004
1 sentence

2004The decision on a motion under this rule is committed to the sound discretion of the trial judge and will not be reversed on appeal absent a clear showing of abuse of discretion, Scannell v. Ed Ferreirinha & Irmao, Lda., 401 Mass. 155, 157-158 (1987), “that is, if it was a ruling that ‘no conscientious judge, acting intelligently, could honestly’ have made.” Maniscola v. Kenworthy, 2002 Mass. App. Div. 203, 204 , quoting Mazzoleni v. Cotton, 33 Mass. App. Ct. 147, 152-153 (1992), quoting Davis v. Boston Elev.

11
Commonwealth v. Kinggreen
mass · 2002 · cited in 1 Massachusetts opinions naming this issue, 2002–2002
1 sentence

2002For a comprehensive analysis, see generally Commonwealth v. King, 436 Mass. 252, 254-255 (2002).

11
Waltham Tele-Communications v. O'BRIENgreen
mass · 1989 · cited in 1 Massachusetts opinions naming this issue, 1995–1995
1 sentence

1995Waltham Tele-Communications v. O’Brien, 403 Mass. 747, 749 (1989).

11
Davidson v. Davidsongreen
massappct · 1985 · cited in 1 Massachusetts opinions naming this issue, 1990–1990
1 sentence

1990An equitable division should not be ordered in a case where *342 the evidence introduced by the parties does not warrant findings comprehensive of those factors.” Putnam v. Putnam, 5 Mass. App. Ct. 10, 17 (1977). 4 Lest the provisions of the judgment ordering conveyances of the properties in question be misinterpreted as an equitable division, possibly precluding an equitable division in the future (see Maze v. Mihalovich, 1 Mass. App. Ct. 323, 324-326 [1979]; Davidson v. Davidson, 19 Mass. App. Ct. 364, 367-368 [1985]), the judgment should be clarified to state expressly that the conveyances

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Department of Revenue v. W.Z. green
mass · 1992
1 sentence

2025As part of that framework, "[m]otions under rule 60 (b) (1), (2), and (3) must be brought at least within one year of the challenged order." Department of Revenue v. W.Z., 412 Mass. 718 , 721 n.4 (1992), citing Chavoor v. Lewis, 383 Mass. 801, 803 (1981).

12025–2025
School Committee of Newton v. Labor Relations Comm. green
mass · 1983
1 sentence

2017Appellate courts in the Commonwealth have held that a public employer violates the obligation to bargain in good faith when the employer refuses to bargain at all, id. at 574-575 , or when it reaches an agreement with a union but then makes its execution contingent on approval by a supervisory entity, Springfield Hous.

12017–2017
Boston Bicycle Couriers, Inc. v. Deputy Director of the Division of Employment & Training green
massappct · 2002
2 sentences

2015While “[n]o one factor is outcome-determinative,” id., it is fair to say that an important element of a working relationship is the contract responsible for creating it.

2015Further, any determination as to whether the plaintiffs have satisfied the statutory requirements of the Wage Act, and established their status as employees, ought to “be based upon a comprehensive analysis of the totality of relevant facts and circumstances of the working relationship.” Id. at 484 .

12015–2015
Athol Daily News v. Board of Review of the Division of Employment & Training green
mass · 2003
1 sentence

2014The critical question here is “whether the service in question could be viewed as an independent trade or business because the worker is capable of performing the service to anyone wishing to avail themselves of the services or, conversely, whether the nature of the business compels the worker to depend on a single employer for the continuation of the services.” Id. at 181 . “[T]he question whether an employer has satisfied the statutory requirements of the third prong of [the independent contactor test] must be based upon a comprehensive analysis of the totality of relevant facts and circumst

12014–2014
Maniscola v. Kenworthy green
massdistctapp · 2002
1 sentence

2004The decision on a motion under this rule is committed to the sound discretion of the trial judge and will not be reversed on appeal absent a clear showing of abuse of discretion, Scannell v. Ed Ferreirinha & Irmao, Lda., 401 Mass. 155, 157-158 (1987), “that is, if it was a ruling that ‘no conscientious judge, acting intelligently, could honestly’ have made.” Maniscola v. Kenworthy, 2002 Mass. App. Div. 203, 204 , quoting Mazzoleni v. Cotton, 33 Mass. App. Ct. 147, 152-153 (1992), quoting Davis v. Boston Elev.

12004–2004
Putnam v. Putnam green
massappct · 1979
1 sentence

1980Her order encompasses “all substantial assets jointly owned and any separate property representing accretion during the marriage, [and is clearly] based on a comprehensive analysis of all major elements of contribution by the spouses during the marriage.” Putnam v. Putnam, 7 Mass. App. Ct. at 673 , quoting Putnam v. Put *732 nam, 5 Mass. App. Ct. 10, 17 (1977).

11980–1980
Nowell A. Brathwaite v. John R. Manson, Commissioner of Correction of the State of Connecticut green
ca2 · 1976
1 sentence

1976A recent case, Brathwaite v. Manson, 527 F.2d 363 (2d Cir. 1975) (Friendly, J.), after a comprehensive analysis, concludes that Biggers applies only to pre- Stovall identifications and was not intended to alter the law as to later cases. 14 4.

11976–1976

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 30A, § 14 (4) MA § Mass. Gen. Laws ch. 231, § 118 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NJ 189 (1956–2026) CA 126 (1916–2026) NY 115 (1856–2026) PA 109 (1904–2026) FL 68 (1934–2021) OH 47 (1916–2025) TX 46 (1926–2026) IL 24 (1884–2026) WA 23 (1967–2024) MA 23 (1976–2025) IN 22 (1980–2025) MD 21 (1916–2025) CT 21 (1929–2017) TN 21 (1977–2025) CO 19 (1953–2025) MO 17 (1906–2023) WY 17 (1957–2016) NM 16 (2003–2025) MI 14 (1957–2016) AZ 14 (1955–2020) IA 13 (1963–2018) UT 13 (1937–2020) KS 12 (1973–2026) ND 12 (1961–2015) NC 11 (1955–2022) MN 9 (1949–2017) LA 9 (1947–2021) MT 9 (1951–2025) AK 8 (1972–2026) VA 8 (1963–2024) HI 8 (1942–2023) DC 8 (1978–2022) OK 7 (1928–2019) ME 7 (1972–2003) WV 7 (1981–2015) MS 7 (1902–2014) GA 6 (1958–2022) NH 6 (1958–2008) WI 6 (1916–2000) ID 6 (1975–2019) DE 6 (1881–1996) NV 6 (2009–2015) KY 6 (1929–2025) SC 5 (1992–2025) OR 5 (1979–2021) VI 4 (2012–2014) AR 3 (1954–2016) SD 3 (1974–1992) RI 3 (1975–1990) NE 3 (1938–2019) VT 2 (2007–2007)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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