REGISTER OF DEEDS FOR NORFOLK COUNTY v. COUNTY DIRECTOR FOR NORFOLK COUNTY & Others

CourtMassachusetts Supreme Judicial Court
DecidedFebruary 14, 2025
DocketSJC-13669
StatusPublished

This text of REGISTER OF DEEDS FOR NORFOLK COUNTY v. COUNTY DIRECTOR FOR NORFOLK COUNTY & Others (REGISTER OF DEEDS FOR NORFOLK COUNTY v. COUNTY DIRECTOR FOR NORFOLK COUNTY & Others) is published on Counsel Stack Legal Research, covering Massachusetts Supreme Judicial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
REGISTER OF DEEDS FOR NORFOLK COUNTY v. COUNTY DIRECTOR FOR NORFOLK COUNTY & Others, (Mass. 2025).

Opinion

SUPREME JUDICIAL COURT

REGISTER OF DEEDS FOR NORFOLK COUNTY vs. COUNTY DIRECTOR FOR NORFOLK COUNTY & others[1]

Docket: SJC-13669
Dates: December 2, 2024 – February 14, 2025
Present: Budd, C.J., Gaziano, Kafker, Wendlandt, Georges, Dewar, & Wolohojian, JJ.
County: Norfolk
Keywords: Register of Deeds. County, Commissioners. Practice, Civil, Declaratory proceeding, Action in nature of mandamus, Injunctive relief, Summary judgment. Declaratory Relief. Mandamus. Injunction. Statute, Construction. Words, "Opinion."

      Civil action commenced in the Superior Court Department on October 21, 2022.

      The case was heard by Michael A. Cahillane, J., on motions for summary judgment, and a motion for reconsideration was considered by him.

      The Supreme Judicial Court on its own initiative transferred the case from the Appeals Court.

      Joshua M.D. Segal (Scott P. Lopez also present) for the defendants.

      William P. O'Donnell, pro se.

      KAFKER, J.  The plaintiff register of deeds for Norfolk County (register of deeds) commenced a lawsuit against the defendant county commissioners for Norfolk County (county commissioners) seeking declaratory, mandamus, and injunctive relief in connection with certain funding and personnel matters within the registry of deeds for Norfolk County (personnel litigation).  More specifically, the plaintiff and the defendant county commissioners disagreed about hiring a new chief information officer, and the funding for that position, which resulted in a lawsuit.  While that litigation was pending, the plaintiff asked the defendant county director for Norfolk County (county director)[2] to make a series of transfers of funds within a "main group" of the budget of the registry of deeds for Norfolk County (registry of deeds) to fund the personnel litigation, pursuant to G. L. c. 35, § 32, stating that in the plaintiff's "opinion" the transfers were of "public necessity and a matter of convenience."  The county director did not approve the requests and instead asked the plaintiff to provide further justification for his opinion, which the plaintiff did not do.  The plaintiff then commenced a second lawsuit, against both the defendant county commissioners and county director, again seeking declaratory, mandamus, and injunctive relief (transfer request litigation).  The two actions were consolidated, and the plaintiff moved for summary judgment in the transfer request litigation.  After a hearing, a judge of the Superior Court allowed the plaintiff's motion for summary judgment on the basis that, pursuant to G. L. c. 35, § 32, the transfer of such funds within a "main group" of the registry of deeds's budget "may be made by the authorized official . . . whenever in his opinion public necessity and convenience so requires" and the defendants did not have the authority to deny the requested transfers.  The defendants timely appealed.  We affirm. 

      1.  Facts and procedural history.  a.  Personnel litigation.  On July 14, 2021, the plaintiff register of deeds brought suit in the Superior Court against the defendant county commissioners, seeking a declaratory judgment, mandamus, and injunctive relief requiring the defendants to approve his request to hire a chief information officer.[3]

      b.  Budget requests.  On May 11, 2022, the Norfolk County advisory board adopted Norfolk County's budget for fiscal year 2023 (FY 2023), which ran from July 1, 2022, to June 30, 2023.  The allocation for the registry of deeds included six main budget groups.  One such main group, "Main Group 2 -- Contractual Services," included, inter alia, the following subclasses:  "legal fees," "computer hardware," "misc. contractual services," "misc. prof. & technical services," "travel out of state," and "travel in state."  The subclasses "legal fees" and "computer hardware" were allocated $7,000 and $125,000, respectively. 

      On July 7, 2022, the plaintiff sent a supplemental budget request to the defendant county commissioners requesting an additional $60,000 for legal fees.  On September 14, 2022, the advisory board on county expenditures approved an additional $20,000 for legal fees.  The plaintiff made a second supplemental request on September 22, 2022, for an additional $75,000 for legal fees to fund the personnel litigation. 

      On the day before the plaintiff made his second supplemental budget request for additional funds, he made the first of four contested requests to transfer funds within the Contractual Services main group.  On September 21, 2022, the first assistant register of deeds submitted a request on behalf of the plaintiff to the county director, seeking the transfer of $1,500 each from both Contractual Services subclasses "travel out of state" and "travel in state" to a third Contractual Services subclass, "misc. contractual services."  The request stated that it was the plaintiff's opinion that the request was "of public necessity and a matter of convenience."  The county director did not approve the request.  On October 11, 2022, the plaintiff sent an additional three requests to the county director to transfer funds between subclasses within the Contractual Services main group.  The plaintiff requested the transfer of $75,000 from the "computer hardware" subclass to the "legal fees" subclass, $18,000 from the "computer hardware" subclass to the "misc. contractual services" subclass, and $32,000 from the "computer hardware" subclass to the "misc. prof. & technical services" subclass.  These transfer requests represented the entirety of the funds allocated to the computer hardware subclass for FY 2023.  In each request, the plaintiff cited to G. L. c. 35, § 32, and stated:  "It is my opinion that this request is of a public necessity and a matter of convenience."  On October 17, 2022, the county director sent an e-mail message to the plaintiff to request a justification for the "public necessity" and "convenience."  The plaintiff did not provide an explanation.  

      c.  Transfer request litigation.  On October 21, 2022, the plaintiff brought a second suit in the Superior Court against the defendant county commissioners and county director, seeking declaratory, mandamus, and injunctive relief requiring the defendants to make the four requested budget transfers.  The plaintiff sought a preliminary injunction, which a judge of the Superior Court denied, finding that the plaintiff failed to show a substantial likelihood of success on the merits.

      The defendants filed a motion to consolidate the suits, which was allowed.  The plaintiff moved for judgment on the pleadings and summary judgment as to the budget transfers, and the defendants cross-moved for summary judgment.  After a hearing, a different judge of the Superior Court granted summary judgment in favor of the plaintiff, concluding that the defendants were obligated to comply with the plaintiff's budget transfer requests, which satisfied the relevant statutory requirements. 

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REGISTER OF DEEDS FOR NORFOLK COUNTY v. COUNTY DIRECTOR FOR NORFOLK COUNTY & Others, Counsel Stack Legal Research, https://law.counselstack.com/opinion/register-of-deeds-for-norfolk-county-v-county-director-for-norfolk-county-mass-2025.