Bay State Harness Horse Racing & Breeding Ass'n v. State Racing Commission

Summary

The Massachusetts Supreme Judicial Court considered a challenge to the State Racing Commission’s issuance of a 1959 harness-racing license to Eastern Racing Association. The court stated that local approval of a race-track location was not required again when statutory amendments later permitted nighttime harness racing. The appeal was ultimately dismissed as moot because the 1959 racing season had ended, although the court addressed the recurring statutory issue.

Holdings

1. The case was moot because the 1959 harness races had already been run and the court could grant no relief concerning them.
2. The 1946 amendment authorizing harness racing between 7 p.m. and midnight did not impose a new requirement for local approval when the location of the track had previously been approved for horse racing.

Questions Presented

1. Whether the appeal concerning the 1959 racing license had become moot after the 1959 races were completed.
2. Whether the 1946 statutory authorization of nighttime harness racing required Eastern to obtain a new or separate local approval for nighttime harness racing at Suffolk Downs.
3. Whether Bay State was a person aggrieved under G. L. c. 30A, § 14.

Disposition

affirmed