COMPLAINT FOR JUDICIAL REVIEW OF LICENSING DECISION

CAPTION

SUPERIOR COURT OF MASSACHUSETTS, [COUNTY] COUNTY
[PETITIONER/LICENSEE], Plaintiff,
v.
[AGENCY/BOARD NAME], Defendant.
Case No.: [___]

INTRODUCTION

• Complaint for judicial review under M.G.L. c. 30A, Section 14, challenging Defendant's [Denial/Discipline/Suspension/Revocation] of [License Type] issued [DATE].

JURISDICTION, VENUE, AND TIMELINESS

• Jurisdiction under the Massachusetts Administrative Procedure Act (M.G.L. c. 30A, Section 14); venue proper in [County].
• Complaint timely under M.G.L. c. 30A, Section 14 (30 days from receipt of notice of final decision).
• Administrative remedies exhausted.

PARTIES

• Plaintiff [Name], license number [___].
• Defendant [Agency/Board], state agency located in [County/City].

PROCEDURAL HISTORY

• Summary of accusation/notice, hearing date(s), agency decision, and service of final decision on [DATE].

STANDARD AND GROUNDS (M.G.L. c. 30A, Section 14)

• The court may set aside the agency decision if it determines that the substantial rights of any party may have been prejudiced because the decision is: (1) in violation of constitutional provisions; (2) in excess of statutory authority; (3) based upon an error of law; (4) made upon unlawful procedure; (5) unsupported by substantial evidence; (6) unwarranted by facts found by the court on the record; or (7) arbitrary or capricious, an abuse of discretion, or otherwise not in accordance with law.
• [Tailor to record].

ALLEGATIONS (SUMMARY)

• [Facts showing evidentiary gaps, legal errors, bias, or procedural defects].

RELIEF REQUESTED

• Issue order directing Defendant to vacate the decision and [reinstate license/issue license/remand].
• Stay enforcement pending review.
• Costs and other relief as just.

VERIFICATION AND SIGNATURE

• Verification per applicable Massachusetts rules; signature of Plaintiff/counsel; proof of service on Defendant and Attorney General.