SARA CLINE & Others v. PLANNING BOARD OF FRAMINGHAM & Others

CourtMassachusetts Appeals Court
DecidedOctober 16, 2025
Docket24-P-160
StatusPublished

This text of SARA CLINE & Others v. PLANNING BOARD OF FRAMINGHAM & Others (SARA CLINE & Others v. PLANNING BOARD OF FRAMINGHAM & Others) 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
SARA CLINE & Others v. PLANNING BOARD OF FRAMINGHAM & Others, (Mass. Ct. App. 2025).

Opinion

APPEALS COURT

SARA CLINE & others[1] vs. PLANNING BOARD OF FRAMINGHAM & others[2]

Docket: 24-P-160
Dates: January 6, 2025 – October 16, 2025
Present: Englander, Hodgens, & Smyth, JJ.
County: Middlesex
Keywords: Zoning, Appeal, Person aggrieved, Special permit. Practice, Civil, Zoning appeal, Standing, Summary judgment. Municipal Corporations, Planning board.

      Civil action commenced in the Superior Court Department on September 21, 2021.

      The case was heard by Shannon Frison, J., on motions for summary judgment.

      Benjamin B. Tymann for the plaintiffs.

      Bridget Bradley, First Assistant City Solicitor, for planning board of Framingham.

      Michael A. Kelly for Leonard P. Belli & another.

      HODGENS, J.  Following public hearings, codefendant planning board of Framingham (board) granted zoning relief to codefendant Universal Property Management, LLC (applicant), for the construction of a carwash and coffee shop.  The plaintiff homeowners (plaintiffs or abutters) appealed by filing a complaint in the Superior Court.  A judge allowed motions for summary judgment filed by the board and the applicant, concluding that the abutters lacked standing and that they had failed to support a claim that the board's decision was arbitrary or capricious.  Although we conclude that the abutters have standing, we discern no error on review of the merits of the board's action and affirm.

      Background.  On July 1, 2021, the applicant petitioned the board for zoning relief on seven contiguous parcels along Worcester Road (Route 9) to raze existing structures and build a carwash and adjoining coffee shop (project).  The parcels are positioned between Wheeler Avenue and Curve Street within a district zoned for business and a highway corridor overlay.  Pursuant to the Framingham zoning bylaws, the applicant sought approval of its site plan as well as five special permits for carwash use, fast food service, drive-thru operation, land disturbance and stormwater management, and public way access.  The board held two public hearings on July 22 and August 5 and unanimously approved the requested relief at a public meeting on August 19.  On September 3, an eleven-page decision followed, approving the plan and special permits and including forty-eight conditions.

      On September 21, the abutters, who reside on Curve Street, filed their complaint in the Superior Court.  They claimed that the board's decision was arbitrary, capricious, and legally untenable, and they sought review through G. L. c. 40A, § 17, as well as through an action in the nature of certiorari under G. L. c. 249, § 4.  Specifically, they alleged that the project would harm their property interests by causing "severe safety concerns," substantially increased vehicle traffic, and other adverse impacts related to noise, odor, health, visual, stormwater, and environmental conditions.  Expert affidavits followed (discussed more fully below) after the board and the applicant filed motions for summary judgment.  The abutters produced an affidavit from a professional engineer who offered opinions on traffic safety, and the applicant produced affidavits from two professional engineers generally rejecting any suggestion that the project would cause adverse impacts of any kind.  Among other things, the abutters' expert opined that some of the vehicles leaving the proposed businesses would exit onto Curve Street, where the abutters lived, and that the unusual configuration of Curve Street would lead to significant traffic safety concerns.  Allowing the motions for summary judgment filed by the board and the applicant, the judge viewed the abutters' claims as "insufficient to support standing" and further concluded that the abutters failed to produce any support for the claim that the board acted in an arbitrary or capricious manner.

      Discussion.  1.  Challenging decision of permit granting authority.  As an initial matter, a challenge to a decision of a permit granting authority is governed by G. L. c. 40A, § 17.  That statute directs parties seeking to appeal the decision to file a civil complaint with a request that a court annul the decision.  Id.  An action in the nature of certiorari, however, is available to correct errors in proceedings "not otherwise reviewable by motion or by appeal."  G. L. c. 249, § 4.  Put another way, a court's power to exercise certiorari review provides a remedy where none would otherwise exist.  See Cumberland Farms, Inc. v. Planning Bd. of Bourne, 56 Mass. App. Ct. 605, 608 (2002).  Because "a zoning appeal pursuant to G. L. c. 40A, § 17, provided a reasonably adequate remedy in this case," certiorari was not available.  Id.  Review of the board's decision is, therefore, properly limited to the standards developed under G. L. c. 40A, § 17.

      2.  Standing.  We apply de novo review to the judge's summary judgment decision on standing.  Stone v. Zoning Bd. of Appeals of Northborough, 496 Mass. 366, 373 (2025), citing 81 Spooner Rd., LLC v. Zoning Bd. of Appeals of Brookline, 461 Mass. 692, 699 (2012).  "Courts are not established to enable parties to litigate matters in which they have no interest affecting their liberty, rights or property."  Hogarth-Swann v. Weed, 274 Mass. 125, 132 (1931).  "[T]o preserve orderly administrative processes and judicial review thereof, a party must meet the legal requirements necessary to confer standing."  Save the Bay, Inc. v. Department of Pub. Utils., 366 Mass. 667, 672 (1975).  "Standing is the gateway through which one must pass en route to an inquiry on the merits."  Reynolds v. Zoning Bd. of Appeals of Stow, 88 Mass. App. Ct. 339, 345 (2015).  "[A] plaintiff ultimately bears the burden of establishing standing."  Murchison v. Zoning Bd. of Appeals of Sherborn, 485 Mass. 209, 213 (2020).

      a.  Presumption of standing.  Only a municipal officer or board or a "person aggrieved by a decision of the board of appeals or any special permit granting authority" may challenge that decision in court.  G. L. c. 40A, § 17.  See 81 Spooner Rd., LLC, 461 Mass. at 700 n.12 (status as aggrieved person under G. L. c. 40A, § 17, is "jurisdictional prerequisite" for judicial review).  "Abutters are entitled to a rebuttable presumption that they are 'aggrieved' persons under the Zoning Act [(G. L. c. 40A)] and, therefore, have standing to challenge a decision of a zoning board of appeals [or other permit granting authority]."  Id. at 700.

      Based upon our review of the record (and our view that the 2024 amendments to G. L. c. 40A, § 17, do not apply to the circumstances presented here),[3] we conclude that the plaintiffs, who own properties within the requisite proximity to the proposed project, enjoyed presumptive standing as abutters.  Plaintiffs Lauren Dobish and Paul Rutherford are direct abutters, and plaintiff Sara Cline is an abutter to an abutter within 300 feet of the subject property.  Given their distinctive locations in relation to the subject property, the plaintiffs are presumed to be "person[s] aggrieved" under G. L. c. 40A, § 17.  See, e.g., Choate v. Zoning Bd.

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SARA CLINE & Others v. PLANNING BOARD OF FRAMINGHAM & Others, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sara-cline-others-v-planning-board-of-framingham-others-massappct-2025.