MacLaurin v. City of HolyokeAnnotate this Case
Mass. Gen. Laws ch. 148, 26I, the residential sprinkler provision, mandates the installation of automatic sprinklers in certain buildings. Plaintiff, the owner of two vacant apartment buildings that he intended to return to occupancy, argued that the rehabilitation he undertook to the buildings did not trigger the requirement that sprinklers be installed. The City of Holyoke’s fire chief ordered that automatic sprinkler systems be installed in each building. McLaurin then filed these complaints seeking relief in the nature of certiorari and declaratory, arguing that the orders were arbitrary and capricious. A judge of the Housing Court affirmed the chief’s orders. The Supreme Judicial Court vacated the judgment affirming the fire chief’s decision, holding that the Housing Court judge was not in a position to ascertain whether the decision was legally erroneous or arbitrary and capricious. Remanded to the fire chief for further proceedings.