Summary
The Massachusetts Supreme Judicial Court affirmed the denial of Jose L. Negron's request for relief in the nature of mandamus concerning access to a correctional work-release program and the housing of parolees and nonparolees. The court held that adequate alternative remedies were available, including declaratory and injunctive relief and administrative grievance procedures, and that the requested actions were discretionary rather than ministerial. The court also concluded that relief under G. L. c. 211, § 3, was unavailable because the defendants were executive officials rather than inferior courts.
Topics
Practice areas
Questions Presented
- Whether the single justice abused his discretion or committed an error of law by denying relief in the nature of mandamus.
- Whether mandamus relief was available when the plaintiff had adequate alternative remedies, including declaratory and injunctive relief and administrative grievance procedures followed by judicial review.
- Whether mandamus could compel correctional officials to permit work outside the facility when the governing statute and regulations made that decision discretionary.
- Whether relief under G. L. c. 211, § 3, was available against executive correctional officials.
Holdings
- Relief in the nature of mandamus under G. L. c. 249, § 5, is unavailable unless the plaintiff demonstrates the absence of an adequate and effective alternative remedy. Because Negron could pursue declaratory and injunctive relief and administrative grievance procedures followed by judicial review, mandamus was properly denied.
- Relief in the nature of mandamus is inappropriate when the plaintiff seeks to compel actions that are discretionary rather than ministerial.
- Relief under G. L. c. 211, § 3, was properly denied because the Supreme Judicial Court's superintendence power extends only to courts of inferior jurisdiction and does not authorize superintendence over executive agencies.
Key quotations
“Where a plaintiff seeks relief in the nature of mandamus pursuant to G. L. c. 249, § 5, "relief is available only where the [plaintiff] demonstrates the absence of an adequate and effective alternative remedy."” (at 2)
“In addition, relief in the nature of mandamus is inappropriate where a plaintiff "seeks to compel actions that are discretionary rather than ministerial"” (at 2-3)
Factual background
Negron alleged that parolees at a minimum-security Department of Correction facility were denied participation in a statutory work-release program while nonparolee inmates were permitted to participate. He claimed that the disparate access violated due process, equal protection, state and federal statutes, and Department of Correction regulations. He also alleged that parolees and nonparolees should not be housed together and sought orders compelling correctional officials to remedy both conditions.
Procedural history
Negron filed a complaint seeking an order requiring correctional officials to remedy alleged unequal access to a work-release program and to house parolees separately from nonparolees. A single justice denied relief, concluding that the allegations did not establish a failure of justice warranting mandamus. The Supreme Judicial Court affirmed, holding that adequate alternative remedies existed and that the requested actions were discretionary rather than ministerial.