JEFFREY A. KING & Another v. CONSERVATION COMMISSION OF HARWICH (And a Consolidated Case).

CourtMassachusetts Appeals Court
DecidedJanuary 30, 2026
Docket24-P-1186
StatusUnpublished

This text of JEFFREY A. KING & Another v. CONSERVATION COMMISSION OF HARWICH (And a Consolidated Case). (JEFFREY A. KING & Another v. CONSERVATION COMMISSION OF HARWICH (And a Consolidated Case).) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
JEFFREY A. KING & Another v. CONSERVATION COMMISSION OF HARWICH (And a Consolidated Case)., (Mass. Ct. App. 2026).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

24-P-1186

JEFFREY A. KING & another1

vs.

CONSERVATION COMMISSION OF HARWICH (and a consolidated case2).

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The plaintiffs appeal from two Superior Court judgments

that affirmed separate orders of the conservation commission of

Harwich (commission) concerning the plaintiffs' violations of

the town of Harwich's wetlands protection bylaw (bylaw) on the

plaintiffs' property. The first order found that the plaintiffs

had unlawfully constructed an addition and porch within fifty

feet of a wetland, and it required them to remove those

structures. The second order denied the plaintiffs' application

1 James M. Kelly.

2Jeffrey A. King & another vs. Conservation Commission of Harwich. for what was in effect a variance to allow the structures to

remain. We affirm the judgments upholding the orders.

Background. We recite the facts as they appear in the

records of the two commission proceedings, as filed by the

commission in response to the Superior Court complaints. We

reserve certain details for later discussion.

1. Enforcement proceeding. In May 2016, the commission's

administrator met with one of the plaintiffs at the property and

found that the plaintiffs, without a permit, had constructed a

porch and addition within the fifty-foot "no-disturb zone" that

section 310-2.A of the bylaw and section 1.04(3) of the

commission's wetland protection regulations (regulations)

establish around wetlands in Harwich.3 The administrator issued

an order directing the plaintiffs or their representative to

appear at a show-cause hearing before the commission to discuss

the matter. At that hearing, the plaintiffs were represented by

Arthur Lafranchise, a friend who had a small financial interest

in the property. Lafranchise acknowledged that the construction

had occurred without a permit. The hearing was continued to a

3 The administrator also found that the construction violated G. L. c. 131, § 40, the State wetlands protection act (WPA). The ensuing commission proceedings thus involved the enforcement of the WPA as well as the town bylaw. We need not discuss the WPA aspect of the proceedings except when relevant to specific issues the plaintiffs raise on appeal.

2 future commission meeting to allow for submission of additional

information.

When the hearing resumed in July 2016, the commission had

before it a 2016 plan, and other materials prepared for the

plaintiffs, showing the new porch and a ten-foot by twelve-foot

addition as entirely within a line fifty feet from the edge of

the wetland (i.e., entirely within the no-disturb zone).

Lafranchise argued that, rather than requiring removal of the

new structures, the commission should impose a significant fine.

The commission voted to find the plaintiffs in violation of the

bylaw and to require the structures' removal. In its written

decision, the commission further found that the plaintiffs' new

porch was, at its closest point, only nine feet from the edge of

the wetland.

The plaintiffs sought certiorari review in Superior Court.

The commission answered and counterclaimed for enforcement of

its order. The plaintiffs moved to dismiss the counterclaims on

the ground that the commission lacked standing to seek

enforcement of its order; a judge (first judge) denied that

motion. On the parties' cross motions for judgment on the

pleadings, the first judge ordered judgment affirming the

commission's decision and, on the commission's counterclaims,

3 requiring the plaintiffs to remove the structures and restore

the area to its previous condition. The plaintiffs appealed.

2. Variance proceeding. On May 4, 2017, while the first

Superior Court case was pending, the plaintiffs filed with the

commission an after-the-fact notice of intent, which included an

application for a variance from the no-disturb-zone bylaw, to

allow the structures to remain in place. The plaintiffs' filing

included a written waiver of the statutory requirement for a

hearing within twenty-one days of their application. See G. L.

c. 131, § 40, seventeenth par. The waiver was signed by the

plaintiffs' new representative, Paul Shea. The commission began

its hearing on June 7, 2017, continued it to and completed it on

June 21, 2017, and thereafter timely issued a decision denying

the variance request.

The plaintiffs then commenced a second Superior Court

action, seeking certiorari review of the commission's variance

decision. On the parties' cross motions for judgment on the

pleadings, a judge (second judge) affirmed the decision. The

plaintiffs again appealed, and their two appeals were

consolidated in this court.

4 Discussion. We review the commission's enforcement order

to determine if it was arbitrary and capricious.4 See Garrity v.

Conservation Comm'n of Hingham, 462 Mass. 779, 792 (2012). We

will review the commission's variance decision as we would a

wetlands permit decision; such "review is limited at most to

whether the commission's decision is supported by substantial

evidence in the administrative record . . . [or] arbitrary and

capricious, and whether the commission committed an abuse of

discretion or other error of law." Delapa v. Conservation

Comm'n of Falmouth, 93 Mass. App. Ct. 729, 733–734 (2018). In a

certiorari case, "[b]ecause we are reviewing the same record of

[commission] proceedings as was before the Superior Court, we

review the record . . . without giving the view of the Superior

Court judge any special weight" (quotation and citation

omitted). P.J. Keating Co. v. Acushnet, 104 Mass. App. Ct. 65,

69–70 (2024).

4 We need not determine whether the plaintiffs are correct in arguing, that the enforcement order must also be supported by substantial evidence, or that, to obtain a judicial enforcement order, the commission must prove the existence of a violation. See Fafard v. Conservation Comm'n of Reading, 41 Mass. App. Ct. 565, 567-568 (1996); Bourne v. Austin, 19 Mass. App. Ct. 738, 742 (1985), citing Brotherhood of Alpha Upsilon, Inc. v. Zoning Bd. of Appeals of Bridgewater, 15 Mass. App. Ct. 991, 992 (1983). The commission's enforcement order and its filings in Superior Court meet those standards in any event.

5 1. Evidence supporting enforcement order. The plaintiffs

first argue that there is insufficient evidence in the record to

support the commission's enforcement order. Because the

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Bluebook (online)
JEFFREY A. KING & Another v. CONSERVATION COMMISSION OF HARWICH (And a Consolidated Case)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeffrey-a-king-another-v-conservation-commission-of-harwich-and-a-massappct-2026.