Pielech v. Massasoit Greyhound, Inc.

Summary

The Massachusetts Supreme Judicial Court held that retroactive application of a 1997 amendment to G. L. c. 151B, § 4 (1A), which expanded protection for sincerely held religious beliefs, violated the defendant’s due process rights under art. 10 of the Massachusetts Declaration of Rights and the Fourteenth Amendment. The court vacated the judgment for the plaintiffs, directed entry of judgment for the defendant, and affirmed denial of the plaintiffs’ motion to amend their complaint to add a Title VII claim.

Holdings

1. Retroactive application of the 1997 amendment violated the defendant's due-process rights under art. 10 of the Massachusetts Declaration of Rights and the Fourteenth Amendment because the amendment imposed a new and substantial employment-discrimination obligation based on sincerely held religious beliefs for conduct occurring when that obligation did not exist.
2. The Superior Court judge did not commit legal error or abuse his discretion by denying the plaintiffs' motion to amend their complaint to add a Title VII claim.

Questions Presented

1. Whether retroactive application of the 1997 amendment to G. L. c. 151B, § 4 (1A), violated the defendant's due-process rights under the Fourteenth Amendment to the United States Constitution and art. 10 of the Massachusetts Declaration of Rights.
2. Whether the Superior Court judge abused his discretion or committed legal error by denying the plaintiffs' motion to amend their complaint to add a Title VII claim.

Disposition

vacated