MacLaurin v. City of Holyoke, 475 Mass. 231

Background

Plaintiff Robert MacLaurin bought two vacant multiunit residential buildings in Holyoke and rehabilitated them under building permits; he submitted sprinkler narrative plans but disputed that work triggered sprinkler retrofit.
Holyoke fire chief inspected the properties and ordered automatic sprinkler systems installed, concluding the buildings were “substantially rehabilitated so as to constitute the equivalent of new construction.”
The residential-sprinkler statute (G. L. c.148, §26I) requires sprinklers in new multiunit residential buildings and in existing ones only when substantially rehabilitated to be equivalent to new construction; it contains no statutory right of appeal.
MacLaurin sought administrative review, was denied jurisdiction, then filed certiorari and declaratory relief in court; the Housing Court affirmed the fire chief after remand; the case was transferred to the SJC.
The SJC construed the undefined statutory phrase and held that “substantially rehabilitated so as to constitute the equivalent of new construction” means work rendering the building, as a whole, essentially as good as new (e.g., materials, systems, market value, useful life), a higher threshold than “major alteration.”
Because the fire chief’s orders lacked explicit findings, a clear interpretive test, and factual determinations (e.g., scope of openings, cost comparisons), the SJC vacated the affirmance and remanded the matter to the fire chief for proceedings consistent with its standard; the Court also said a hearing would have been appropriate under the circumstances.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Meaning of statutory phrase “substantially rehabilitated so as to constitute the equivalent of new construction”	MacLaurin: renovations were not that extensive and did not render buildings equivalent to new construction	Holyoke: work undertaken was sufficiently extensive; similar to commercial “major alteration” test	The phrase requires rehabilitation that renders the whole building essentially as good as new; higher threshold than “major alteration”
Standard of review in certiorari (no statutory appeal)	MacLaurin: need meaningful review and findings; arbitrariness due to lack of hearing and record	Holyoke: chief’s on-site inspection and discretion entitled to deference	Review limited to legal error or arbitrary/capricious; deference only if decision aligns with statutory purpose and supported by facts; current record insufficient
Adequacy of fire chief’s decision (findings and reasoning)	MacLaurin: orders lack factual findings, cost analysis, and misstate scope of work	Holyoke: relied on inspections, cost/value considerations, and comparisons to appeals board decisions	Orders deficient: no explicit findings, no articulation of test, and failure to address key factual disputes; remand required
Need for an evidentiary hearing / due process	MacLaurin: hearing required to develop record and protect property owner from potentially ruinous cost	Holyoke: statute contains no hearing/appeal; chief acted within administrative discretion	Although not deciding constitutional dimension, court held a hearing would have been appropriate here given lack of authority, disputed facts, and absence of appellate review route

Key Cases Cited

Boston Police Patrolmen's Ass'n v. Boston, 435 Mass. 718 (statutory interpretation principles)
State Bd. of Retirement v. Woodward, 446 Mass. 698 (certiorari review standard for discretionary administrative decisions)
Figgs v. Boston Housing Auth., 469 Mass. 354 (purpose of certiorari to remedy errors when no other remedy exists)
Congregation Beth Sholom & Community Center, Inc. v. Building Comm'r of Framingham, 27 Mass. App. Ct. 276 (interpretation of “major alterations” in commercial-sprinkler context)
Yerardi's Moody St. Restaurant & Lounge v. Selectmen of Randolph, 19 Mass. App. Ct. 296 (hearings and protections where government exerts power in matters of consequence)
MacHenry v. Civil Service Comm'n, 40 Mass. App. Ct. 632 (standard for correcting substantial errors of law on certiorari)