Summary
The Massachusetts Supreme Judicial Court dismissed as moot Doyle’s appeal from a single justice’s denial of his request to further stay entry of judgment in the Goodridge litigation. The court held that the judgment had already been entered and stated that, even on the merits, the single justice had acted within his discretion in denying the requested stay.
Topics
Practice areas
Questions Presented
- Whether the appeal from the single justice's denial of a further stay was moot after the Superior Court entered the judgment.
- Whether the single justice erred or abused his discretion in denying Doyle's request for a further stay.
Holdings
- The appeal was moot because the judgment whose entry Doyle sought to stay had already been entered in the Superior Court.
- Even if the court reached the merits, the single justice correctly acted within his discretion in denying Doyle's request for a further stay.
Key quotations
“That question is purely academic at this point. The judgment, entry of which Doyle sought to have stayed, was in fact entered in the Superior Court on May 17, 2004, pursuant to the terms of our rescript. We therefore dismiss his appeal as moot.” (1007)
“Appeal dismissed.” (1007)
Factual background
The Supreme Judicial Court's Goodridge decision held that excluding same-sex couples from civil marriage violated the Massachusetts Constitution and directed entry of a consistent judgment after a 180-day stay. Doyle was not a party to that case but sought an additional stay while the Legislature considered constitutional amendments. Before the full court decided his appeal, the Superior Court entered the judgment whose entry Doyle sought to delay.
Procedural history
In Goodridge, the Supreme Judicial Court vacated summary judgment for the defendants and remanded for entry of judgment, staying entry for 180 days. Doyle, who was not a party to Goodridge, petitioned a single justice to extend the stay pending a proposed constitutional amendment process. The single justice denied relief, and while Doyle's appeal was pending, the Superior Court entered the judgment on May 17, 2004; the full court also denied Doyle's request for a further stay.