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Howe v. Attorney General

Citations: 90 N.E.2d 316; 325 Mass. 268; 1950 Mass. LEXIS 1055

Court: Massachusetts Supreme Judicial Court; February 3, 1950; Massachusetts; State Supreme Court

Narrative Opinion Summary

The case involves petitioners who were the original signers of an initiative petition concerning state-controlled liquor stores. They sought a writ of mandamus to compel the Attorney General to certify their petition as valid for submission to the public. The Attorney General had declined certification, citing the petition's failure to meet the 'proper form' requirement established by Article XLVIII of the Massachusetts Constitution and its relevance to matters excluded from initiative proposals. The court dismissed the petition for mandamus, ruling that it was not the appropriate remedy since the Attorney General had already taken definitive action by refusing certification. The court indicated that certiorari would be a more suitable remedy for reviewing substantive legal errors from quasi-judicial decisions. Additionally, the court noted procedural deficiencies, such as the lack of a motion to amend the petition and the expiration of the deadline for additional signatures. Consequently, the petition was dismissed, affirming the Attorney General's decision and denying the relief sought by the petitioners.

Legal Issues Addressed

Appropriate Remedy for Quasi-Judicial Errors

Application: The court suggested that certiorari was more suitable than mandamus for addressing substantive legal errors by a quasi-judicial body like the Attorney General.

Reasoning: The court emphasized that certiorari, rather than mandamus, would be the suitable remedy for substantive legal errors from a quasi-judicial body.

Certification Requirements for Initiative Petitions

Application: The court referred to the constitutionally mandated requirements for initiative petitions, emphasizing that the Attorney General must ensure the petition is in proper form.

Reasoning: The petition, submitted in July 1949, was declined certification by the Attorney General on the grounds that it was not in 'proper form' as per Article XLVIII of the Massachusetts Constitution and related to matters excluded from initiative proposals.

Mandamus as a Remedy

Application: The court determined that mandamus was inappropriate because the petitioners sought a review of the Attorney General's decision, which had already been made.

Reasoning: The court determined that mandamus was not the appropriate remedy since the Attorney General had taken action by refusing certification, and the petitioners essentially sought a review of that decision.