St. George Greek Orthodox Cathedral of Western Massachusetts, Inc. v. Fire Department, 967 N.E.2d 127

Legislature empowered the State board of building regulations and standards to adopt and administer a statewide building code.
The code 780 CMR 907.14.3 prescribes four fire protective signaling/automatic fire detection options.
Springfield enacted a 2006 ordinance requiring only the fourth option and imposing daily fines for noncompliance.
St. George Greek Orthodox Cathedral installed the first option system during 2009 renovations and was fined by the city.
The board ruled the church complied with the code and lacked authority to invalidate the ordinance; the church sued for declaratory relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preemption of the Springfield ordinance	Code preempts local action; ordinance is inconsistent with statewide standards.	Ordinance narrows options but is not inconsistent with the code.	Yes; the code preempts the ordinance.
Declaratory relief appropriateness	Declaratory judgment is appropriate to resolve the ordinance's validity.	Administrative remedies and posture may limit relief; not essential here.	Yes; declaratory relief appropriate to determine validity.

Wendell v. Attorney Gen., 394 Mass. 518 (1985) (preemption analysis and field occupation by State law)
Bloom v. Worcester, 363 Mass. 136 (1973) (legislative intent to preclude local action when comprehensive statute exists)
Connors v. Boston, 430 Mass. 31 (1999) (local action must be precluded when state law aims for uniform standards)
Lovequist v. Conservation Comm’n of Dennis, 379 Mass. 7 (1979) (local minimum standards not controlling where state act occupies field)
Dartmouth v. Greater New Bedford Regional Vocational Tech. High Sch. Dist., 461 Mass. 366 (2012) (comprehensive legislation precludes local regulation that would frustrate purpose)
Boston Gas Co. v. Somerville, 420 Mass. 702 (1995) (regulatory deference to properly promulgated state regulations)