relatedness requirement in Massachusetts

2026See Hensley, 11 474 Mass. at 659 , quoting Albano v. Attorney Gen., 437 Mass. 156, 161 (2002) (petition "does not fail the relatedness requirement just because it affects more than one statute, as long as [its] provisions . . . are related by a common purpose").

2024Although there is no doubt that Version B would work a change across the entirety of our General and Special Laws, "[a] measure does not fail the relatedness requirement just because it affects more than one statute, as long as the provisions of the petition are related by a common purpose." Albano v. Attorney Gen., 437 Mass. 156, 161 (2002).

2015Relatedness The relatedness requirement stipulates that the action complained of must “directly arise out of the specific contacts between the defendant and the forum state.” Fern v. Immergut, 55 Mass.App.Ct. 577, 584 (2002), citing Sawtelle v. Farrell 70 F.3d 1381, 1389 (1st Cir. 1995).

2002“The relatedness requirement is not met merely because a plaintiff’s cause of action arose out of the general relationship between the parties; rather, the action must directly arise out of the specific contacts between the defendant and the forum state.” Id. at 1389 (emphasis supplied).

2018The relatedness requirement was imposed in its current form, mandating that initiative petitions contain only subjects that are "related" or "mutually dependent," after much debate among the delegates about how best to avoid "packaging proposed laws in a way that would confuse the voter," Carney I, 447 Mass. at 228 , or otherwise be "misleading." See id. at 225 , 227-230 & n.21.6 "To prevent initiative petitions from being exploited in As an example of impermissible log-rolling, the delegates 6 to the convention debated a provision placed before voters in Oregon through an initiative process:

2018The relatedness requirement was imposed in its current form, mandating that initiative petitions contain only subjects that are "related" or "mutually dependent," after much debate among the delegates about how best to avoid "packaging proposed laws in a way that would confuse the voter," Carney I , 447 Mass. at 228 , 850 N.E.2d 521 , or otherwise be "misleading." See id . at 225, 227-230 & n.21, 850 N.E.2d 521 . 6 **788 "To prevent initiative petitions from *316 being exploited in this manner, the delegates considered potential limitations on their subject matter....

2018Because a reasonable voter could not fairly accept or reject the petition as a unified statement of public *324 policy, Initiative Petition 15-17 does not meet the relatedness requirement set forth in art. 48, The Initiative, II, § 3, as amended by art. 74. 9 Including it on the ballot would place a reasonable voter in the "untenable position of casting a single vote on two or **799 more dissimilar subjects." See Abdow , 468 Mass. at 499 , 11 N.E.3d 574 .

2018The relatedness requirement of the language in art. 48, The Initiative, II, § 3, as amended by art. 74, was intended to balance the "interests of initiative petitioners and the interests of those who would ultimately vote on the petition." Abdow , 468 Mass. at 499 , 11 N.E.3d 574 .

2018The Oberlies plaintiffs point to Gray , 474 Mass. at 647 , 52 N.E.3d 1065 , where, in concluding that the proposal did not satisfy the relatedness test, we noted the costs associated with one of the initiative's provisions.

2018The Oberlies plaintiffs point to Gray , 474 Mass. at 647 , 52 N.E.3d 1065 , where, in concluding that the proposal did not satisfy the relatedness test, we noted the costs associated with one of the initiative's provisions.

2026See Hensley, 11 474 Mass. at 659 , quoting Albano v. Attorney Gen., 437 Mass. 156, 161 (2002) (petition "does not fail the relatedness requirement just because it affects more than one statute, as long as [its] provisions . . . are related by a common purpose").

2018Because a reasonable voter could not fairly accept or reject the petition as a unified statement of public policy, Initiative Petition 15-17 does not meet the relatedness requirement set forth in art. 48, The Initiative, II, § 3, as amended by art. 74.9 Including it on the ballot would place a reasonable voter in the "untenable position of 9 Given the result we reach, we need not address the plaintiffs' argument that the petition violates the provision in art. 48, The Initiative, II, § 2, that "[n]o measure . . . that makes a specific appropriation of money from the treasury of the commonwealt

2018See Albano v. Attorney General, 437 Mass. 156, 161 (2002) (discussing "the relatedness requirement" as whether "a petition contains only subjects 'which are related or which are mutually dependent'" and deciding that "entire petition" [with several distinctly separate provisions] shared "[a] common purpose" that was not "so broad as to render the 'related subjects' limitation meaningless" [citations omitted]); Mazzone v. Attorney Gen., 432 Mass. 515, 529 (2000) (under subheading "[r]elated or mutually dependent subjects," discussing and determining that subjects of petition were "related to a

2018See Albano v. Attorney General , 437 Mass. 156 , 161, 769 N.E.2d 1242 (2002) (discussing "the relatedness requirement" as whether "a petition contains only subjects 'which are related or which are mutually dependent' " and deciding that "entire petition" [with several distinctly separate provisions] shared "[a] common purpose" that was not "so broad as to render the 'related subjects' limitation meaningless" [citations omitted] ); Mazzone v. Attorney Gen ., 432 Mass. 515 , 529, 736 N.E.2d 358 (2000) (under subheading "[r]elated or mutually dependent subjects," discussing and determining that s

2015Relatedness The relatedness requirement stipulates that the action complained of must “directly arise out of the specific contacts between the defendant and the forum state.” Fern v. Immergut, 55 Mass.App.Ct. 577, 584 (2002), citing Sawtelle v. Farrell 70 F.3d 1381, 1389 (1st Cir. 1995).

2015Astro-Med, Inc., 591 F.3d at 9 (citation omitted) (relatedness satisfied as defendant’s conduct occurring in Florida and California, which amounted to breach of contract, caused injury to the plaintiff in Rhode Island). b.

2015Hahn v. Vermont Law School, 698 F.2d 48, 51 (1st Cir. 1983) (where the cause of action is for breach of contract, and the business transacted was the formation of the contract, the relatedness requirement is satisfied).

2014See United States v. Swiss Am Bank, Ltd., 274 F.3d 610, 624 (1st Cir. 2001) (noting that in Calder v. Jones, 465 U.S. 783, 786, 790 (1984), the Supreme Court did not need to address relatedness prong even though the only contacts between one Colder defendant and forum were that his article was published within forum and legal injury occurred within forum; both in-forum publication and in-forum injury were clearly related to plaintiffs defamation suit); Farquharson v. Metz, 2013 U.S. Dist.

2014See United States v. Swiss Am Bank, Ltd., 274 F.3d 610, 624 (1st Cir. 2001) (noting that in Calder v. Jones, 465 U.S. 783, 786, 790 (1984), the Supreme Court did not need to address relatedness prong even though the only contacts between one Colder defendant and forum were that his article was published within forum and legal injury occurred within forum; both in-forum publication and in-forum injury were clearly related to plaintiffs defamation suit); Farquharson v. Metz, 2013 U.S. Dist.

2002See Foster-Miller, Inc. v. Babcock & Wilcox Canada, 46 F.3d 138 , 144-145 & n.3 (1st Cir. 1995) (evaluating relatedness requirement reduces to whether the plaintiff’s claim arises from the defendant’s minimum contacts).