interests standard (Massachusetts) · Go Syfert
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interests standard in Massachusetts

18 Massachusetts opinions name it 2 courts 1975–2018 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 (18)

CaseFollowedCited
Petition of the New England Home for Little Wanderersgreen
mass · 1975 · cited in 3 Massachusetts opinions naming this issue, 1978–2001
2 sentences

2001L. c. 210, § 3, “will vary with the circumstances.” See Adoption of Hugo, 428 Mass. 219, 231 (1998), quoting Petition of the New England Home for Little Wanderers to Dispense with Consent to Adoption, 367 Mass. 631, 644 (1975).

1978Little Wanderers, supra at 644 .

23
Adoption of Vitogreen
mass · 2000 · cited in 2 Massachusetts opinions naming this issue, 2003–2018
2 sentences

2018See Adoption of Vito , 431 Mass. at 566 .

2003See Youmans v. Ramos, 429 Mass. 774, 785 (1999) (court may order visitation between child and de facto parent when it is in best interests of child); Adoption of Vito, 431 Mass. at 563-567 (postadoption visitation with biological mother); Blixt v. Blixt, 437 Mass. 649, 657-660 (2002), cert. denied, 537 U.S. 1189 (2003) (grandparents where parents are unmarried); R.J.A. v. K.A.V., 34 Mass. App. Ct. 369, 373 (1993) (best interest of child standard should be predominant factor in determining what rights, if any, putative father had).

22
Youmans v. Ramosgreen
mass · 1999 · cited in 2 Massachusetts opinions naming this issue, 2003–2007
2 sentences

2007Similarly, in Youmans v. Ramos, 429 Mass. 774, 779 (1999), the court allowed a child’s aunt to visit the child over the objection of a fit legal father, because the aunt had raised the child for almost all of her life until the father asserted his right to custody.

2003See Youmans v. Ramos, 429 Mass. 774, 785 (1999) (court may order visitation between child and de facto parent when it is in best interests of child); Adoption of Vito, 431 Mass. at 563-567 (postadoption visitation with biological mother); Blixt v. Blixt, 437 Mass. 649, 657-660 (2002), cert. denied, 537 U.S. 1189 (2003) (grandparents where parents are unmarried); R.J.A. v. K.A.V., 34 Mass. App. Ct. 369, 373 (1993) (best interest of child standard should be predominant factor in determining what rights, if any, putative father had).

22
Adoption of Hugogreen
mass · 1998 · cited in 2 Massachusetts opinions naming this issue, 2001–2003
2 sentences

2003When addressing the sibling relationship, the Supreme Judicial Court has rejected the argument that the sibling relationship is entitled to any heightened protection, Adoption of Hugo, 428 Mass. 219, 230-231 (1998), and has concluded that while it is “preferable that siblings be raised together ... the weight to be accorded sibling relations in the application of the best interests standard . . . ‘will vary with the circumstances.’ ” Adoption of Willow, 433 Mass. 636, 651 (2001), quoting from Adoption of Hugo, supra at 231.

2003When addressing the sibling relationship, the Supreme Judicial Court has rejected the argument that the sibling relationship is entitled to any heightened protection, Adoption of Hugo, 428 Mass. 219, 230-231 (1998), and has concluded that while it is “preferable that siblings be raised together ... the weight to be accorded sibling relations in the application of the best interests standard . . . ‘will vary with the circumstances.’ ” Adoption of Willow, 433 Mass. 636, 651 (2001), quoting from Adoption of Hugo, supra at 231.

22
Adoption of a Minorgreen
mass · 1975 · cited in 2 Massachusetts opinions naming this issue, 1982–1999
2 sentences

1999The best interests standard presents the trial judge “with a classic example of a discretionary decision.” Adoption of a Minor (No. 2), 367 Mass. 684, 688 (1975).

1982We have stated that the best interests standard presents “the trial judge with a classic example of a discretionary decision.” Adoption of a Minor (No. 2), 367 Mass. 684, 688 (1975).

22
Guardianship of Roegreen
mass · 1981 · cited in 2 Massachusetts opinions naming this issue, 1993–1993
2 sentences

1993See Guardianship of Roe, 383 Mass. 415, 425, 448 (1981); Rogers v. Commissioner of the Dept. of Mental Health, 390 Mass. 489, 505, 506 (1983); Guardianship of Doe, 411 Mass. 512, 523-524 (1992).

1993See Guardianship of Roe, 383 Mass. 415, 425, 448 (1981); Rogers v. Commissioner of the Dept. of Mental Health, 390 Mass. 489, 505, 506 (1983); Guardianship of Doe, 411 Mass. 512, 523-524 (1992).

22
Rogers v. Commissioner of the Department of Mental Healthgreen
mass · 1983 · cited in 2 Massachusetts opinions naming this issue, 1993–1993
2 sentences

1993See Guardianship of Roe, 383 Mass. 415, 425, 448 (1981); Rogers v. Commissioner of the Dept. of Mental Health, 390 Mass. 489, 505, 506 (1983); Guardianship of Doe, 411 Mass. 512, 523-524 (1992).

1993See Guardianship of Roe, 383 Mass. 415, 425, 448 (1981); Rogers v. Commissioner of the Dept. of Mental Health, 390 Mass. 489, 505, 506 (1983); Guardianship of Doe, 411 Mass. 512, 523-524 (1992).

22
Guardianship of Doegreen
mass · 1992 · cited in 2 Massachusetts opinions naming this issue, 1993–1993
2 sentences

1993See Guardianship of Roe, 383 Mass. 415, 425, 448 (1981); Rogers v. Commissioner of the Dept. of Mental Health, 390 Mass. 489, 505, 506 (1983); Guardianship of Doe, 411 Mass. 512, 523-524 (1992).

1993See Guardianship of Roe, 383 Mass. 415, 425, 448 (1981); Rogers v. Commissioner of the Dept. of Mental Health, 390 Mass. 489, 505, 506 (1983); Guardianship of Doe, 411 Mass. 512, 523-524 (1992).

22
Custody of a Minorgreen
mass · 1978 · cited in 2 Massachusetts opinions naming this issue, 1982–1992
2 sentences

1992As a practical matter, the criteria to be examined and the basic applicable reasoning are the same." (Citation omitted.) Custody of a Minor (No. 1), 385 Mass. 697 , 710 n. 10 (1982), quoting Custody of a Minor, 375 Mass. 733, 753 (1978). [12] The judge did not address two other State interests, the protection of innocent third parties and prevention of suicide, as they are not relevant to this case.

1992As a practical matter, the criteria to be examined and the basic applicable reasoning are the same.” (Citation omitted.) Custody of a Minor (No. 1), 385 Mass. 697 , 710 n.10 (1982), quoting Custody of a Minor, 375 Mass. 733, 753 (1978).

22
Adoption of Donaldgreen
massappct · 2001 · cited in 1 Massachusetts opinions naming this issue, 2013–2013
1 sentence

2013See Adoption of Donald, 52 Mass. App. Ct. at 902 ; Adoption of Scott, 59 Mass. App. Ct. at 277 ; Adoption of Gillian, 63 Mass. App. Ct. at 408 ; Adoption of Nate, 69 Mass. App. Ct. at 375 . 9 In other words, the mother’s reservation of the right to nominate her parents as an adoptive resource or a guardianship, and to have the judge consider that plan, does not confer upon her the right to challenge the judge’s determination, after entry of the decree terminating her parental rights, that the department’s competing plan for adoption is in Malik’s best interests — particularly in the circumstan

11
Dickenson v. Cogswellgreen
massappct · 2006 · cited in 1 Massachusetts opinions naming this issue, 2007–2007
1 sentence

2007See Dickenson v. Cogswell, 66 Mass. App. Ct. 442, 449 (2006); Pizzino v. Miller, 67 Mass. App. Ct. 865, 874 (2006). 2 , 3 Trial judges have been applying the best interests test for decades, and typically do so in a highly competent manner; they are well versed, as here, in the considerations that must be balanced. 4 “The trial judge is in a position far superior to our own with respect to these judgments, and absent an abuse of discretion, we do not presume to interfere.” Pizzino v. Miller, 67 Mass. App. Ct. at 872 .

11
Pizzino v. Millergreen
massappct · 2006 · cited in 1 Massachusetts opinions naming this issue, 2007–2007
2 sentences

2007See Dickenson v. Cogswell, 66 Mass. App. Ct. 442, 449 (2006); Pizzino v. Miller, 67 Mass. App. Ct. 865, 874 (2006). 2 , 3 Trial judges have been applying the best interests test for decades, and typically do so in a highly competent manner; they are well versed, as here, in the considerations that must be balanced. 4 “The trial judge is in a position far superior to our own with respect to these judgments, and absent an abuse of discretion, we do not presume to interfere.” Pizzino v. Miller, 67 Mass. App. Ct. at 872 .

2007See Dickenson v. Cogswell, 66 Mass. App. Ct. 442, 449 (2006); Pizzino v. Miller, 67 Mass. App. Ct. 865, 874 (2006). 2 , 3 Trial judges have been applying the best interests test for decades, and typically do so in a highly competent manner; they are well versed, as here, in the considerations that must be balanced. 4 “The trial judge is in a position far superior to our own with respect to these judgments, and absent an abuse of discretion, we do not presume to interfere.” Pizzino v. Miller, 67 Mass. App. Ct. at 872 .

11
E.N.O. v. L.M.M.green
mass · 1999 · cited in 1 Massachusetts opinions naming this issue, 2006–2006
1 sentence

2006See, e.g., E.N.O. v. L.M.M., 429 Mass. 824, 829 (1999).

11
Adoption of Willowgreen
mass · 2001 · cited in 1 Massachusetts opinions naming this issue, 2003–2003
1 sentence

2003When addressing the sibling relationship, the Supreme Judicial Court has rejected the argument that the sibling relationship is entitled to any heightened protection, Adoption of Hugo, 428 Mass. 219, 230-231 (1998), and has concluded that while it is “preferable that siblings be raised together ... the weight to be accorded sibling relations in the application of the best interests standard . . . ‘will vary with the circumstances.’ ” Adoption of Willow, 433 Mass. 636, 651 (2001), quoting from Adoption of Hugo, supra at 231.

11
Blixt v. Blixtgreen
mass · 2002 · cited in 1 Massachusetts opinions naming this issue, 2003–2003
1 sentence

2003See Youmans v. Ramos, 429 Mass. 774, 785 (1999) (court may order visitation between child and de facto parent when it is in best interests of child); Adoption of Vito, 431 Mass. at 563-567 (postadoption visitation with biological mother); Blixt v. Blixt, 437 Mass. 649, 657-660 (2002), cert. denied, 537 U.S. 1189 (2003) (grandparents where parents are unmarried); R.J.A. v. K.A.V., 34 Mass. App. Ct. 369, 373 (1993) (best interest of child standard should be predominant factor in determining what rights, if any, putative father had).

11
Rja v. Kavgreen
massappct · 1993 · cited in 1 Massachusetts opinions naming this issue, 2003–2003
1 sentence

2003See Youmans v. Ramos, 429 Mass. 774, 785 (1999) (court may order visitation between child and de facto parent when it is in best interests of child); Adoption of Vito, 431 Mass. at 563-567 (postadoption visitation with biological mother); Blixt v. Blixt, 437 Mass. 649, 657-660 (2002), cert. denied, 537 U.S. 1189 (2003) (grandparents where parents are unmarried); R.J.A. v. K.A.V., 34 Mass. App. Ct. 369, 373 (1993) (best interest of child standard should be predominant factor in determining what rights, if any, putative father had).

11
Superintendent of Belchertown State School v. Saikewiczgreen
mass · 1977 · cited in 1 Massachusetts opinions naming this issue, 1978–1978
1 sentence

1978Compare Superintendent of Belchertown State School v. Saikewicz, supra, with Petition of the New England Home for Little Wanderers to Dispense with Consent to Adoption, 367 Mass. 631, 640-641, 644 (1975).

11
Richards v. Forrestgreen
mass · 1932 · cited in 1 Massachusetts opinions naming this issue, 1975–1975
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 (15)

CaseCitedYears
Adoption of Dora green
massappct · 2001
1 sentence

2013Id. at 476 . 8 We acknowledge that the stipulation entered into by the mother included a provision in which the mother purported to “reserve[] her right as to the best interests hearing concerning placement of [Malik], The mother’s desire is that her parents adopt [Malik].” Upon entry of the decree terminating the mother’s parental rights, however, such a provision at most had the effect of assuring the judge’s consideration of the mother’s proposed kinship adoption nominees, and not of imbuing her with a legal status, or legal rights, that are inconsistent with the rights of a biological pare

12013–2013
Adoption of Scott green
massappct · 2003
1 sentence

2013See Adoption of Donald, 52 Mass. App. Ct. at 902 ; Adoption of Scott, 59 Mass. App. Ct. at 277 ; Adoption of Gillian, 63 Mass. App. Ct. at 408 ; Adoption of Nate, 69 Mass. App. Ct. at 375 . 9 In other words, the mother’s reservation of the right to nominate her parents as an adoptive resource or a guardianship, and to have the judge consider that plan, does not confer upon her the right to challenge the judge’s determination, after entry of the decree terminating her parental rights, that the department’s competing plan for adoption is in Malik’s best interests — particularly in the circumstan

12013–2013
Adoption of Gillian green
massappct · 2005
1 sentence

2013See Adoption of Donald, 52 Mass. App. Ct. at 902 ; Adoption of Scott, 59 Mass. App. Ct. at 277 ; Adoption of Gillian, 63 Mass. App. Ct. at 408 ; Adoption of Nate, 69 Mass. App. Ct. at 375 . 9 In other words, the mother’s reservation of the right to nominate her parents as an adoptive resource or a guardianship, and to have the judge consider that plan, does not confer upon her the right to challenge the judge’s determination, after entry of the decree terminating her parental rights, that the department’s competing plan for adoption is in Malik’s best interests — particularly in the circumstan

12013–2013
Adoption of Nate green
massappct · 2007
1 sentence

2013See Adoption of Donald, 52 Mass. App. Ct. at 902 ; Adoption of Scott, 59 Mass. App. Ct. at 277 ; Adoption of Gillian, 63 Mass. App. Ct. at 408 ; Adoption of Nate, 69 Mass. App. Ct. at 375 . 9 In other words, the mother’s reservation of the right to nominate her parents as an adoptive resource or a guardianship, and to have the judge consider that plan, does not confer upon her the right to challenge the judge’s determination, after entry of the decree terminating her parental rights, that the department’s competing plan for adoption is in Malik’s best interests — particularly in the circumstan

12013–2013
Tazziz v. Tazziz green
massappct · 1988
1 sentence

2010The standard does not focus on “purely parental interests,” Tazziz, 26 Mass. App. Ct. at 813 , and significantly, it requires a gender-neutral analysis.

12010–2010
A.H. v. M.P. green
mass · 2006
1 sentence

2007In A. H., the court revisited the best interests analysis in this context, stating: “The focus on caretaking in the ALI Principles is one means by which to anchor the best interests of the child analysis in an objectively reasonable assessment of whether disruption of the adult-child relationship is potentially harmful to the child’s best interests.” A.H., supra at 839-840 , citing ALI Principles § 2.02 comment b, at 96.

12007–2007
Goodridge v. Department of Public Health green
mass · 2003
1 sentence

2007Of course, “the best interests standard comes into play only after a judge has determined that a ‘significant preexisting relationship’ has created the requisite parent-child attachment that argues for visitation.” Ibid.

12007–2007
Blue Ribbon Properties, Inc., Dba Long Hollow Landfill v. Hardin County Fiscal Court green
scotus · 2003
1 sentence

2003See Youmans v. Ramos, 429 Mass. 774, 785 (1999) (court may order visitation between child and de facto parent when it is in best interests of child); Adoption of Vito, 431 Mass. at 563-567 (postadoption visitation with biological mother); Blixt v. Blixt, 437 Mass. 649, 657-660 (2002), cert. denied, 537 U.S. 1189 (2003) (grandparents where parents are unmarried); R.J.A. v. K.A.V., 34 Mass. App. Ct. 369, 373 (1993) (best interest of child standard should be predominant factor in determining what rights, if any, putative father had).

12003–2003
Taylor v. Commonwealth green
mass · 1975
1 sentence

1993Requiring further disclosures in this context does not significantly endanger the interests which the privilege protects.” Id. at 190 .

11993–1993
Custody of a Minor green
mass · 1982
2 sentences

1992As a practical matter, the criteria to be examined and the basic applicable reasoning are the same." (Citation omitted.) Custody of a Minor (No. 1), 385 Mass. 697 , 710 n. 10 (1982), quoting Custody of a Minor, 375 Mass. 733, 753 (1978). [12] The judge did not address two other State interests, the protection of innocent third parties and prevention of suicide, as they are not relevant to this case.

1992As a practical matter, the criteria to be examined and the basic applicable reasoning are the same.” (Citation omitted.) Custody of a Minor (No. 1), 385 Mass. 697 , 710 n.10 (1982), quoting Custody of a Minor, 375 Mass. 733, 753 (1978).

11992–1992
Beloin v. Bullett green
mass · 1941
11975–1975
Stinson v. Meegan green
mass · 1945
11975–1975
Riordan's Case green
mass · 1972
2 sentences

1975I disagree. 1 The majority opinion draws support for its interpretation of best interests from cases decided under predecessor statutes to § 3 (see, e.g., Beloin v. Bullett, 310 Mass. 206 [1941]; Adoption of a Minor, 357 Mass. 490 [1970]; Adoption of a Minor, 362 Mass. 882 [1972]) and cases decided in the guardianship context under c. 201, § 5 (see, e.g., Richards v. Forrest, 278 Mass. 547 [1932]; Stinson v. Meegan, 318 Mass. 459 [1945]; Kauch, petitioners, 358 Mass. 327 [1970]).

1975I disagree. [1] *648 The majority opinion draws support for its interpretation of best interests from cases decided under predecessor statutes to § 3 (see, e.g., Beloin v. Bullett, 310 Mass. 206 [1941]; Adoption of a Minor, 357 Mass. 490 [1970]; Adoption of a Minor, 362 Mass. 882 [1972]) and cases decided in the guardianship context under c. 201, § 5 (see, e.g., Richards v. Forrest, 278 Mass. 547 [1932]; Stinson v. Meegan, 318 Mass. 459 [1945]; Kauch, petitioners, 358 Mass. 327 [1970]).

11975–1975
Adoption of a Minor green
mass · 1970
2 sentences

1975I disagree. 1 The majority opinion draws support for its interpretation of best interests from cases decided under predecessor statutes to § 3 (see, e.g., Beloin v. Bullett, 310 Mass. 206 [1941]; Adoption of a Minor, 357 Mass. 490 [1970]; Adoption of a Minor, 362 Mass. 882 [1972]) and cases decided in the guardianship context under c. 201, § 5 (see, e.g., Richards v. Forrest, 278 Mass. 547 [1932]; Stinson v. Meegan, 318 Mass. 459 [1945]; Kauch, petitioners, 358 Mass. 327 [1970]).

1975I disagree. [1] *648 The majority opinion draws support for its interpretation of best interests from cases decided under predecessor statutes to § 3 (see, e.g., Beloin v. Bullett, 310 Mass. 206 [1941]; Adoption of a Minor, 357 Mass. 490 [1970]; Adoption of a Minor, 362 Mass. 882 [1972]) and cases decided in the guardianship context under c. 201, § 5 (see, e.g., Richards v. Forrest, 278 Mass. 547 [1932]; Stinson v. Meegan, 318 Mass. 459 [1945]; Kauch, petitioners, 358 Mass. 327 [1970]).

11975–1975
Kauch green
mass · 1970
2 sentences

1975I disagree. 1 The majority opinion draws support for its interpretation of best interests from cases decided under predecessor statutes to § 3 (see, e.g., Beloin v. Bullett, 310 Mass. 206 [1941]; Adoption of a Minor, 357 Mass. 490 [1970]; Adoption of a Minor, 362 Mass. 882 [1972]) and cases decided in the guardianship context under c. 201, § 5 (see, e.g., Richards v. Forrest, 278 Mass. 547 [1932]; Stinson v. Meegan, 318 Mass. 459 [1945]; Kauch, petitioners, 358 Mass. 327 [1970]).

1975I disagree. [1] *648 The majority opinion draws support for its interpretation of best interests from cases decided under predecessor statutes to § 3 (see, e.g., Beloin v. Bullett, 310 Mass. 206 [1941]; Adoption of a Minor, 357 Mass. 490 [1970]; Adoption of a Minor, 362 Mass. 882 [1972]) and cases decided in the guardianship context under c. 201, § 5 (see, e.g., Richards v. Forrest, 278 Mass. 547 [1932]; Stinson v. Meegan, 318 Mass. 459 [1945]; Kauch, petitioners, 358 Mass. 327 [1970]).

11975–1975

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 210, § 3 (8) MA § Mass. Gen. Laws ch. 119, § 1 (6) MA § Mass. Gen. Laws ch. 119, § 24 (5) MA § Mass. Gen. Laws ch. 119, § 26 (5) MA § Mass. Gen. Laws ch. 210, § 2 (4) MA § Mass. Gen. Laws ch. 119, § 23 (3) MA § Mass. Gen. Laws ch. 215, § 6 (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

NY 414 (1976–2026) NJ 259 (1972–2026) TN 253 (1978–2026) IL 117 (1967–2025) NE 99 (1991–2026) PA 73 (1976–2026) CO 68 (1994–2026) AZ 66 (1923–2025) AK 61 (1975–2026) CA 46 (1930–2026) MI 44 (1879–2025) ND 37 (1999–2025) MD 30 (1992–2024) UT 30 (1919–2024) MN 27 (1980–2024) ID 26 (1928–2026) OH 24 (1992–2024) MO 20 (1889–2022) WY 19 (1990–2026) MA 18 (1975–2018) WI 17 (1973–2024) VA 17 (1999–2022) TX 16 (1949–2020) WA 14 (1978–2024) WV 13 (1987–2024) NC 13 (1993–2020) FL 12 (1987–2018) DC 12 (1978–2010) KY 10 (1998–2025) KS 10 (1917–2019) IA 10 (1894–2022) NM 10 (1991–2024) AL 9 (1981–2006) IN 9 (1993–2018) CT 8 (1979–2016) OR 7 (1986–2025) VT 6 (1991–2018) DE 6 (1984–2023) SD 5 (1996–2023) MT 5 (1989–2004) ME 4 (1990–2010) OK 3 (2000–2013) HI 3 (2006–2024) VI 2 (1978–2016) GA 2 (2005–2026)

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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