exhaustion of administrative remedies doctrine (Massachusetts) · Go Syfert
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exhaustion of administrative remedies doctrine in Massachusetts

10 Massachusetts opinions name it 3 courts 1979–2014 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 (6)

CaseFollowedCited
Broderick's Casegreen
mass · 1946 · cited in 3 Massachusetts opinions naming this issue, 2005–2014
2 sentences

2014In the absence of such a requirement a court would be in the position of reviewing administrative proceedings in a piecemeal fashion, Broderick’s Case, 320 Mass. 149, 151 (1946) ....

2014In the absence of such a requirement a court would be in the position of reviewing administrative proceedings in a piecemeal fashion, Broderick's Case, 320 Mass. 149, 151 (1946) . . . .

33
Murphy v. ADMINISTRATOR OF THE DIV OF PERSONNEL ADMIN.green
mass · 1979 · cited in 3 Massachusetts opinions naming this issue, 1987–2002
2 sentences

2002See Murphy v. Administrator of the Div. of Personnel Admin., 377 Mass. 217, 220 (1979).

1987See Murphy v. Administrator of the Div. of Personnel Admin., supra. Neither party, nor the commission as amicus curiae, argues this point; moreover, such a characterization would not change our analysis in this case.

33
East Chop Tennis Club v. Massachusetts Commission Against Discriminationgreen
mass · 1973 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005The purposes of the doctrine are (a) to permit the administrative agency to apply its presumptive expertise to a dispute within a statutory scheme for which it has primary enforcement responsibility, East Chop Tennis Club v. MCAD, 364 Mass. 444, 451-53 (1973) (leading statement); (b) to permit the agency to undertake competently the technical fact finding within its presumed expertise, Buteau v. Norfolk County Retirement Board, 8 Mass.App.Ct. 391, 394-95 (1979); and (c) to prevent inefficient piecemail judicial review of incomplete administrative adjudicatory proceedings, Broderick’s Case, 320

11
Buteau v. NORFOLK COUNTY RETIREMENT BOARDgreen
massappct · 1979 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005The purposes of the doctrine are (a) to permit the administrative agency to apply its presumptive expertise to a dispute within a statutory scheme for which it has primary enforcement responsibility, East Chop Tennis Club v. MCAD, 364 Mass. 444, 451-53 (1973) (leading statement); (b) to permit the agency to undertake competently the technical fact finding within its presumed expertise, Buteau v. Norfolk County Retirement Board, 8 Mass.App.Ct. 391, 394-95 (1979); and (c) to prevent inefficient piecemail judicial review of incomplete administrative adjudicatory proceedings, Broderick’s Case, 320

11
Trust Insurance v. Commissioner of Insurancegreen
massappct · 2000 · cited in 1 Massachusetts opinions naming this issue, 2004–2004
1 sentence

2004Co. v. Commissioner of Ins., 48 Mass. App. Ct. 617, 624 (2000) (“Allowing administrative agencies to complete their own decision-making processes and discouraging premature judicial intervention are the purposes that underlie the doctrine of exhaustion of administrative remedies”).

11
Gallo v. Division of Water Pollution Controlgreen
mass · 1978 · cited in 1 Massachusetts opinions naming this issue, 1979–1979
1 sentence

1979L. c. 32, § 100, as amended through St. 1978, c. 487, § 18. 1 However, we do not decide these questions because we believe this is a particularly appropriate case in which to apply the doctrine of exhaustion of administrative remedies and to refrain from "frustrating the statutory scheme” (Gallo v. Division of Water Pollution Control, 374 Mass. 278, 288 [1978]) by bypassing the Contributory Retirement Appeal Board.

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 (3)

CaseCitedYears
Athol Memorial Hospital v. Commissioner of the Division of Medical Assistance green
mass · 2002
1 sentence

2010Accordingly, there can be no dispute that, unless they can establish that the circumstances of this case present one of the “rare” exceptions to the doctrine of exhaustion of administrative remedies, Athol, supra, 437 Mass, at 426, the plaintiffs must first pursue those remedies.

12010–2010
Stock v. Massachusetts Hospital School green
mass · 1984
2 sentences

2010In support of that proposition, plaintiffs cite Stock, supra, 392 Mass. at 212-13 , where the court stated that the doctrine of primary jurisdiction [i.e., prior resort to court before any administrative action is begun, which is the functional equivalent of the doctrine of exhaustion of administrative remedies] is limited by several exceptions.

2010In support of that proposition, plaintiffs cite Stock, supra, 392 Mass. at 212-13 , where the court stated that the doctrine of primary jurisdiction [i.e., prior resort to court before any administrative action is begun, which is the functional equivalent of the doctrine of exhaustion of administrative remedies] is limited by several exceptions.

12010–2010
Saint Luke's Hospital v. Labor Relations Commission green
mass · 1946
1 sentence

2000The rationale for the imposed doctrine of exhaustion of administrative remedies in the context of declaratory judgment actions is to permit the agency to complete its assessment of the evidence and its fact finding, including the exercise of its technical and professional expertise. 2 See id. at 469 .

12000–2000

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 30A, § 14 (5)

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 235 (1941–2026) TX 89 (1973–2025) NY 79 (1958–2026) PA 78 (1969–2026) IL 71 (1963–2025) CT 48 (1983–2026) NJ 39 (1952–2025) OH 36 (1990–2025) AZ 29 (1957–2025) MD 26 (1982–2020) MI 26 (1972–2026) AL 25 (1976–2025) IN 25 (1977–2019) ME 24 (1974–2024) AR 22 (1988–2025) MO 18 (1969–2025) WI 15 (1972–2026) AK 14 (1985–2023) NM 13 (1998–2026) UT 13 (1993–2020) CO 12 (1982–2012) FL 12 (1958–2022) DC 11 (1972–2010) WA 11 (1969–2016) TN 10 (1946–2020) MS 10 (1966–2021) MA 10 (1979–2014) DE 10 (1992–2025) SC 10 (1977–2023) MN 10 (1957–2007) KS 9 (1986–2021) NC 8 (2008–2020) RI 7 (1966–2017) WV 7 (1966–2026) IA 7 (1971–2016) NH 6 (1998–2018) HI 6 (2012–2025) GA 5 (1986–2017) WY 4 (1982–2020) OK 4 (1980–2005) VT 3 (1952–2001) ID 3 (1990–2023) SD 3 (1975–1987) LA 3 (1976–2024) NV 3 (1979–2021) NE 2 (1998–2017) OR 2 (1997–2019) ND 2 (2014–2024) VA 2 (2000–2010) MT 2 (2022–2024)

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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