15 Massachusetts opinions name it 3 courts 1935–2025 2 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.
| Case | Followed | Cited |
|---|---|---|
Hansen v. Commonwealthgreen2 sentences2025L. c. 12, §§ 11H-11J, or the Federal Civil Rights Act, 42 U.S.C. § 1983 , both of which allow claims against only those defendants who are "persons." DCF does not qualify as a "person" under either statute. "[T]here is no indication in the MCRA that the word 'person' includes either the Commonwealth or any of its political subdivisions." Howcroft v. Peabody, 51 Mass. App. Ct. 573, 592 (2001). "[I]t is a widely accepted rule of statutory construction that general words in a statute such as 'persons' will not ordinarily be construed to include the State or political subdivisions thereof." Hansen 2022See Hansen v. Commonwealth, 344 Mass. 214, 219 (1962) ("it is a widely accepted rule of statutory construction that general words in a statute . . . will not ordinarily be construed to include the State or political subdivisions thereof"). | 9 | 10 |
Perez v. Boston Housing Authoritygreen2 sentences2015Auth., 368 Mass. 333, 339 (1975) (“werecognize that ‘[i]t is a widely accepted rule of statutoiy construction that general words in a statute such as ‘persons’ will not ordinarily be construed to include the State or political subdivisions thereof,’ ” quoting Hansen v. Commonwealth, 344 Mass. 214, 219 (1962)). 2014Auth., 368 Mass. 333, 339 (1975), quoting Hansen v. Commonwealth, 344 Mass. 214, 219 (1962) (“[i]t is a widely accepted rule of statutory construction that general words in a statute such as ‘persons’ will not ordinarily be construed to include the State or political subdivisions thereof”). | 3 | 4 |
United States v. United Mine Workers of Americagreen2 sentences2005The court expressly stated, “it is a widely accepted rule of statutory construction that general words in a statute such as ‘persons’ will not ordinarily be construed to include the State or political subdivisions thereof.” Ibid., citing United States v. United Mine Workers of America, 330 U.S. 258, 275-276 (1947), and collecting cases. 1962United States v. United Mine Wkrs. of America, 330 U. S. 258, 275 . | 1 | 2 |
Commonwealth v. ELM Medical Laboratories, Inc.green2 sentences2003Bretton v. State Lottery Commission, supra, Commonwealth v. Elm Medical Laboratories, Inc, 33 Mass.App.Ct. 71 (1972). 2001Labs., Inc., 33 Mass. App. Ct. 71, 74-80 (1992). 23 See also Hansen v. Commonwealth, 344 Mass. 214, 219 (1962) (“it is a widely accepted rule of statutory construction that general words in a statute such as ‘persons’ will not ordinarily be construed to include the State or political subdivisions thereof”); Planned Parenthood League of Mass., Inc. v. Blake, 417 Mass. 467 , 473 n.8 (“[t]he Massachusetts Civil Rights Act was enacted in response to deprivations of secured rights by private individuals using violence or threats of violence”), cert. denied, 513 U.S. 868 (1994); Sarvis v. Boston Saf | 1 | 2 |
Laubinger v. Department of Revenuegreen1 sentence2025And "an agency of the Commonwealth is not a 'person' subject to suit for monetary damages under § 1983." Laubinger v. Department of Revenue, 41 Mass. App. Ct. 598, 601 (1996). | 1 | 1 |
Howcroft v. City of Peabodygreen1 sentence2025L. c. 12, §§ 11H-11J, or the Federal Civil Rights Act, 42 U.S.C. § 1983 , both of which allow claims against only those defendants who are "persons." DCF does not qualify as a "person" under either statute. "[T]here is no indication in the MCRA that the word 'person' includes either the Commonwealth or any of its political subdivisions." Howcroft v. Peabody, 51 Mass. App. Ct. 573, 592 (2001). "[I]t is a widely accepted rule of statutory construction that general words in a statute such as 'persons' will not ordinarily be construed to include the State or political subdivisions thereof." Hansen | 1 | 1 |
Kilbane v. Secretary of Human Servicesgreen1 sentence2007A person is defined as “natural persons, corporations, trusts, partnerships, incorporated or unincorporated associations and any other legal entity.” See Bretton v. State Lottery Comm’n., 41 Mass.App.Ct. 736 (1996) (State Lottery Commission, a statutorily created entity, is not a “person" subject to the provision of 93A). “[I]t is a widely accepted rule of statutory construction that general words in a statute such as ‘persons’ will not ordinarily be construed to include the State or political subdivision thereof.” Kilbane v. Secretary of Human Services, 14 Mass.App.Ct. 286, 287 (1982), quotin | 1 | 1 |
Sarvis v. Boston Safe Deposit & Trust Co.green1 sentence2001Labs., Inc., 33 Mass. App. Ct. 71, 74-80 (1992). 23 See also Hansen v. Commonwealth, 344 Mass. 214, 219 (1962) (“it is a widely accepted rule of statutory construction that general words in a statute such as ‘persons’ will not ordinarily be construed to include the State or political subdivisions thereof”); Planned Parenthood League of Mass., Inc. v. Blake, 417 Mass. 467 , 473 n.8 (“[t]he Massachusetts Civil Rights Act was enacted in response to deprivations of secured rights by private individuals using violence or threats of violence”), cert. denied, 513 U.S. 868 (1994); Sarvis v. Boston Saf | 1 | 1 |
Smith v. City of Bostongreen1 sentence1999See Smith v. Boston, 413 Mass. 607 , 611 n.8 (1992). “[I]t is a widely accepted rule of statutory construction that general words in a statute such as ‘persons’ will not ordinarily be construed to include the State or political subdivisions thereof.” Hansen v. Commonwealth, 344 Mass. 214, 219 (1962). | 1 | 1 |
McLouth v. . Huntgreen1 sentence1935McLouth v. Hunt, 154 N. Y. 179, 190, 191, 192 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Bretton v. State Lottery Commission
green
1 sentence2007A person is defined as “natural persons, corporations, trusts, partnerships, incorporated or unincorporated associations and any other legal entity.” See Bretton v. State Lottery Comm’n., 41 Mass.App.Ct. 736 (1996) (State Lottery Commission, a statutorily created entity, is not a “person" subject to the provision of 93A). “[I]t is a widely accepted rule of statutory construction that general words in a statute such as ‘persons’ will not ordinarily be construed to include the State or political subdivision thereof.” Kilbane v. Secretary of Human Services, 14 Mass.App.Ct. 286, 287 (1982), quotin | 1 | 2007–2007 |
Planned Parenthood League of Massachusetts, Inc. v. Blake
green
1 sentence2001Labs., Inc., 33 Mass. App. Ct. 71, 74-80 (1992). 23 See also Hansen v. Commonwealth, 344 Mass. 214, 219 (1962) (“it is a widely accepted rule of statutory construction that general words in a statute such as ‘persons’ will not ordinarily be construed to include the State or political subdivisions thereof”); Planned Parenthood League of Mass., Inc. v. Blake, 417 Mass. 467 , 473 n.8 (“[t]he Massachusetts Civil Rights Act was enacted in response to deprivations of secured rights by private individuals using violence or threats of violence”), cert. denied, 513 U.S. 868 (1994); Sarvis v. Boston Saf | 1 | 2001–2001 |
Blake v. Planned Parenthood League of Massachusetts, Inc.
green
1 sentence2001Labs., Inc., 33 Mass. App. Ct. 71, 74-80 (1992). 23 See also Hansen v. Commonwealth, 344 Mass. 214, 219 (1962) (“it is a widely accepted rule of statutory construction that general words in a statute such as ‘persons’ will not ordinarily be construed to include the State or political subdivisions thereof”); Planned Parenthood League of Mass., Inc. v. Blake, 417 Mass. 467 , 473 n.8 (“[t]he Massachusetts Civil Rights Act was enacted in response to deprivations of secured rights by private individuals using violence or threats of violence”), cert. denied, 513 U.S. 868 (1994); Sarvis v. Boston Saf | 1 | 2001–2001 |
Meyers v. United States
neutral
1 sentence1982Perez v. Boston Housing Authy., 368 Mass. 333, 339 , appeal dismissed, 423 U.S. 1009 (1975). | 1 | 1982–1982 |
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.
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.