savings clause (Massachusetts) · Go Syfert
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savings clause in Massachusetts

20 Massachusetts opinions name it 3 courts 1982–2015 0 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 (13)

CaseFollowedCited
Geier v. American Honda Motor Co.green
scotus · 2000 · cited in 3 Massachusetts opinions naming this issue, 2004–2015
2 sentences

2015That is, even if the savings clause in § 379r(e) “removes tort actions from the scope of [an] express pre-emption clause” such as § 379r(a), the savings clause “does not foreclose ... the possibility that a federal [law] will pre-empt a state common-law tort action with which it conflicts,” see Geier, supra at 869-870 , and principles of implicit conflict preemption would still bar the plaintiffs’ claim if the result the plaintiffs sought would require the defendants to use a warning label that conflicted with FDA requirements.

2015See id. at 871 (without operation of ordinary preemption principles, “state law could impose legal duties that would conflict directly with federal regulatory mandates”).

33
Wilson v. Headgreen
· 1904 · cited in 2 Massachusetts opinions naming this issue, 1995–1995
2 sentences

1995Pittsley, 298 Mass. at 555 ; Wilson v. Head, 184 Mass. 515, 518 (1884).

1995Pittsley, 298 Mass. at 555 ; Wilson v. Head, 184 Mass. 515, 518 (1884).

22
Pittsley v. Davidgreen
mass · 1937 · cited in 4 Massachusetts opinions naming this issue, 1995–1995
2 sentences

1995Pittsley, supra at 555 .

1995Pittsley, 298 Mass. at 555 ; Wilson v. Head, 184 Mass. 515, 518 (1884).

14
Feeney v. Dell Inc.green
mass · 2009 · cited in 1 Massachusetts opinions naming this issue, 2013–2013
1 sentence

2013The Massachusetts Consumer Protection Act “prohibits ‘unfair or deceptive practices in the conduct of any trade or commerce.’ ” Feeney v. Dell Inc., 454 Mass. 192, 212 (2009), quoting G.L.c. 93A, §2(a).

11
Gallant v. Worcestergreen
mass · 1981 · cited in 1 Massachusetts opinions naming this issue, 2012–2012
1 sentence

2012See Section 18 of St. 1978, c. 512; see Gallant v. Worcester, 383 Mass. 707, 710-15 (1981) (actions for injuries from defects of a public way are subject to G.L.c. 84, §15; actions for wrongful death under c. 229 arising out of a defect of a public way are cognizable under c. 258); Trioli v. Town of Sudbury, 15 Mass.App.Ct. 394, 396 (1983) (claims under c. 84 preserved as the exclusive remedy against municipalities for injuries on account of defects in ways since preserved as such under c. 258 legislation).

11
Trioli v. Town of Sudburygreen
massappct · 1983 · cited in 1 Massachusetts opinions naming this issue, 2012–2012
1 sentence

2012See Section 18 of St. 1978, c. 512; see Gallant v. Worcester, 383 Mass. 707, 710-15 (1981) (actions for injuries from defects of a public way are subject to G.L.c. 84, §15; actions for wrongful death under c. 229 arising out of a defect of a public way are cognizable under c. 258); Trioli v. Town of Sudbury, 15 Mass.App.Ct. 394, 396 (1983) (claims under c. 84 preserved as the exclusive remedy against municipalities for injuries on account of defects in ways since preserved as such under c. 258 legislation).

11
State v. Buttongreen
iowa · 2001 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005See, e.g., State v. Brown, 207 Ariz. 231, 233, 235 (Ct. App. 2004) (harassment statute upheld that includes verbal communication “directed at a specific person which would cause a reasonable person to be seriously alarmed, annoyed or harassed and the conduct in fact seriously alarms, annoys or harasses the person” and excludes “otherwise lawful demonstration, assembly or picketing”); Bouters v. State, 659 So. 2d 235, 236-237 (Fla. 1995) (stalking statute constitutional where it defined “harasses” as engaging in a course of conduct which is directed at a person, is wilful and malicious, causes

11
State v. Asmussengreen
sd · 2003 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005See, e.g., State v. Brown, 207 Ariz. 231, 233, 235 (Ct. App. 2004) (harassment statute upheld that includes verbal communication “directed at a specific person which would cause a reasonable person to be seriously alarmed, annoyed or harassed and the conduct in fact seriously alarms, annoys or harasses the person” and excludes “otherwise lawful demonstration, assembly or picketing”); Bouters v. State, 659 So. 2d 235, 236-237 (Fla. 1995) (stalking statute constitutional where it defined “harasses” as engaging in a course of conduct which is directed at a person, is wilful and malicious, causes

11
Bouters v. Stategreen
fla · 1995 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005See, e.g., State v. Brown, 207 Ariz. 231, 233, 235 (Ct. App. 2004) (harassment statute upheld that includes verbal communication “directed at a specific person which would cause a reasonable person to be seriously alarmed, annoyed or harassed and the conduct in fact seriously alarms, annoys or harasses the person” and excludes “otherwise lawful demonstration, assembly or picketing”); Bouters v. State, 659 So. 2d 235, 236-237 (Fla. 1995) (stalking statute constitutional where it defined “harasses” as engaging in a course of conduct which is directed at a person, is wilful and malicious, causes

11
Luplow v. Stategreen
wyo · 1995 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005See, e.g., State v. Brown, 207 Ariz. 231, 233, 235 (Ct. App. 2004) (harassment statute upheld that includes verbal communication “directed at a specific person which would cause a reasonable person to be seriously alarmed, annoyed or harassed and the conduct in fact seriously alarms, annoys or harasses the person” and excludes “otherwise lawful demonstration, assembly or picketing”); Bouters v. State, 659 So. 2d 235, 236-237 (Fla. 1995) (stalking statute constitutional where it defined “harasses” as engaging in a course of conduct which is directed at a person, is wilful and malicious, causes

11
State v. Browngreen
arizctapp · 2004 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005See, e.g., State v. Brown, 207 Ariz. 231, 233, 235 (Ct. App. 2004) (harassment statute upheld that includes verbal communication “directed at a specific person which would cause a reasonable person to be seriously alarmed, annoyed or harassed and the conduct in fact seriously alarms, annoys or harasses the person” and excludes “otherwise lawful demonstration, assembly or picketing”); Bouters v. State, 659 So. 2d 235, 236-237 (Fla. 1995) (stalking statute constitutional where it defined “harasses” as engaging in a course of conduct which is directed at a person, is wilful and malicious, causes

11
Nayor v. Rent Board of Brooklinegreen
mass · 1956 · cited in 1 Massachusetts opinions naming this issue, 1996–1996
1 sentence

1996For this proposition, the landlord relies on Nay or v. Rent Bd. of Brookline, 334 Mass. 132, 135-136 (1956), where it was held that the termination of a previous Brookline rent control statute without a savings clause made moot a pending complaint by a tenant challenging a decision by the board allowing a landlord an increase in rent.

11
cluster 349214green
ca1 · 1977 · cited in 1 Massachusetts opinions naming this issue, 1982–1982
1 sentence

1982See Wadsworth v. Whaland, 562 F.2d 70, 77-79 (1st Cir. 1977); Metropolitan Life Ins.

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 (9)

CaseCitedYears
Offshore Logistics, Inc. v. Tallentire green
scotus · 1986
2 sentences

2007Offshore Logistics, Inc. v. Tallentire, [ 477 U.S. 207 ,] 222-224 [(1986)].

2004Offshore Logistics, Inc. v. Tallentire, supra at 222-224 .

22004–2007
Kilgore v. KeyBank, National Ass'n green
ca9 · 2012
1 sentence

2013VI, and that law renders arbitration agreements enforceable so long as the savings clause is not implicated.” Id. at 963 .

12013–2013
Commonwealth v. a Juvenile green
mass · 1975
2 sentences

2007In order to avoid impermissible conflict with constitutional protections, the court in A Juvenile, supra, engrafted a savings clause onto § 53, holding that the provision may be applied only “to conduct which involves no lawful exercise of a First Amendment right.” Commonwealth v. A Juvenile, supra at 599 .

2007In order to avoid impermissible conflict with constitutional protections, the court in A Juvenile, supra, engrafted a savings clause onto § 53, holding that the provision may be applied only “to conduct which involves no lawful exercise of a First Amendment right.” Commonwealth v. A Juvenile, supra at 599 .

12007–2007
Lann v. United States District Court for the Southern District of Texas green
scotus · 2004
1 sentence

2005See, e.g., State v. Brown, 207 Ariz. 231, 233, 235 (Ct. App. 2004) (harassment statute upheld that includes verbal communication “directed at a specific person which would cause a reasonable person to be seriously alarmed, annoyed or harassed and the conduct in fact seriously alarms, annoys or harasses the person” and excludes “otherwise lawful demonstration, assembly or picketing”); Bouters v. State, 659 So. 2d 235, 236-237 (Fla. 1995) (stalking statute constitutional where it defined “harasses” as engaging in a course of conduct which is directed at a person, is wilful and malicious, causes

12005–2005
CSX Transportation, Inc. v. Easterwood green
scotus · 1993
2 sentences

2005See 49 U.S.C. § 20106 (“A State may adopt or continue in force a law, regulation, or order related to railroad safety until the Secretary of Transportation prescribes a regulation or issues an order covering the subject matter of the State requirement”); CSX Transp., Inc. v. Easterwood, supra. The preemption provision, however, contains a savings clause indicating that a State may adopt or continue in force an additional or more stringent law, regulation, or order when it “is necessary to eliminate or reduce an essentially local safety hazard” (emphasis added). 49 U.S.C. § 20106 (1).

2005CSX Transp., Inc. v. Easterwood, supra. The savings clause relates to specific local hazards that are “aberrations,” involving factors that the Secretary of Transportation did not and, as a practical matter, could not take into account in determining laws or regulations under the FRSA.

12005–2005
Bjorkman v. Suffolk Construction Co. green
massappct · 1997
1 sentence

1997Id.

11997–1997
Farren v. General Motors Corp. green
mad · 1989
1 sentence

1996In support of their argument, plaintiffs cite Farren v. General Motors Corp., 708 F.Supp. 436 , (D.Mass. 1989).

11996–1996
Rogers v. Metropolitan District Commission green
massappct · 1984
2 sentences

1995Id. at 339 .

1995Commn., 18 Mass. App. Ct. 337 (1984), expressly states that the repealing language in that clause “provides . . . that any inconsistent statutory provision not mentioned in the savings clause shall not apply” (emphasis supplied).

11995–1995
Commonwealth v. Federico green
mass · 1981
1 sentence

1982Contrast Commonwealth v. Federico, 383 Mass. 485 (1981) (savings clause for “generally applicable” criminal laws).

11982–1982

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 143, § 51 (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

CA 211 (1947–2026) TX 172 (1947–2025) IL 112 (1952–2023) IN 72 (1971–2026) NY 57 (1946–2026) CT 51 (1985–2025) PA 44 (1953–2025) MS 44 (1958–2024) WA 40 (1971–2026) FL 40 (1979–2026) OH 31 (1966–2025) LA 26 (1941–2021) NJ 21 (1942–2023) IA 21 (1972–2022) MA 20 (1982–2015) MO 20 (1970–2022) AZ 19 (1969–2014) SC 18 (1986–2013) NM 17 (1942–2026) MN 17 (1977–2018) AL 17 (1981–2018) DC 15 (1976–2024) MI 15 (1968–2025) KS 14 (1960–2012) OR 14 (1945–2025) DE 13 (1964–2024) OK 13 (1977–2022) MT 12 (1964–2019) RI 11 (1969–2015) NE 11 (1983–2022) MD 10 (1972–2016) VT 10 (1995–2015) WY 9 (1980–2021) AR 9 (1944–2016) WV 9 (1975–2012) WI 9 (1993–2026) CO 8 (1982–2025) AK 8 (1980–2024) GA 8 (1986–2008) HI 8 (1971–2024) NC 8 (1975–2024) TN 8 (1962–2010) ME 7 (1972–2012) VA 7 (1985–2023) KY 6 (2004–2020) UT 6 (1931–2021) NV 5 (1975–2024) NH 5 (2002–2014) ID 3 (1980–2024) ND 2 (1987–2006) MP 2 (1985–1985)

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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