## Facts

- The Massachusetts Legislature enacted a special statute establishing a fiscal-emergency receivership for the City of Chelsea (the Receivership Act).
- The Act declared that Chelsea faced a fiscal crisis requiring a comprehensive long-term solution and authorized the Governor to appoint a receiver for an initial one-year term.
- The receiver became Chelsea’s chief executive officer, assumed the mayor’s powers, and received additional powers to manage and rehabilitate city operations.
- The Act vacated the mayor’s office during the receivership and limited the board of aldermen to an advisory role.
- The receiver was required to report to the Secretary of Administration, who could reappoint the receiver for additional one-year terms and terminate the receiver for cause.
- After the Act took effect and a receiver was appointed, Chelsea residents and voters sued, seeking a declaration that the Act was unconstitutional and injunctions removing the receiver and restoring elected control.

## Issues

1. Whether the Receivership Act violated the Massachusetts Constitution’s Home Rule Amendment by impermissibly enacting a special law for Chelsea and infringing local self-government in local matters.
2. Whether transferring effective municipal governing authority from elected officials to an appointed receiver violated the Fourteenth Amendment’s Equal Protection Clause under “one person, one vote” principles.

## Decision

- The Supreme Judicial Court upheld the Receivership Act and denied declaratory and injunctive relief.
- The court held the Act did not violate the Home Rule Amendment because the Legislature retained broad authority over municipalities and could respond to a fiscal crisis through a Chelsea-specific law.
- The court held the Act did not violate Equal Protection because “one person, one vote” limits election and apportionment rules and does not bar the creation of appointed offices exercising local executive authority, particularly in a temporary emergency framework.

## Legal Principles

- The Massachusetts Legislature has broad power over municipal structure and governance, limited only by express constitutional constraints, including the Home Rule Amendment.
- A municipality-specific statute may be permissible under the Home Rule Amendment when the Legislature reasonably determines the subject involves state interests beyond purely local concern, such as preserving municipal fiscal integrity and basic governmental operations.
- Home rule does not guarantee an immutable municipal form of government or a permanent allocation of powers to elected local officials.
- The Equal Protection “one person, one vote” doctrine primarily governs electoral representation and apportionment; it does not categorically prohibit appointed officials from exercising substantial governmental authority.
- Temporariness and an emergency fiscal justification support the constitutionality of state intervention that displaces local elected authority for a limited period.

## Conclusion

Massachusetts could temporarily place Chelsea under a state-supervised receivership to address a declared fiscal emergency, even though the statute displaced elected municipal officials, because the intervention fell within legislative authority under the Home Rule Amendment and did not constitute unconstitutional vote dilution under the Fourteenth Amendment.


Powers v. Sec’y of Admin., 412 Mass. 119, 587 N.E.2d 744 (1992)