Panel weighs whether judge’s checkbox form sufficed in sealing petition for dismissed domestic‑violence charges

A three‑justice panel heard arguments over a sealing petition under Massachusetts General Laws c.276 §100C in a case where the petitioner sought review of a judge’s order granting sealing of dismissed or nolle prosequi matters.

Attorney McGrath argued the judge filed a form order with checked factors but did not provide the written explanation required for meaningful appellate review. "We really wanted to put this case up on the merits," McGrath said, urging that the court require more detailed findings when litigants raise public‑safety concerns tied to domestic‑violence patterns.

Anne Maurer, representing the respondent, said the form order that tracked the statutory Pawn factors is an adequate recording of discretionary decisionmaking. She told the panel the judge considered public‑safety concerns and other factors and cited the petitioner’s rehabilitation, housing and work as relevant to sealing relief. Counsel for the Commonwealth noted that automatic sealing schemes in §100A must be read alongside §100C and that the legislature chose a case‑by‑case approach for dismissals.

Justices pressed both sides on how much explanation is required when a judge relies on a standardized form—asking whether more detailed written findings are necessary in cases involving allegations of domestic violence or a pattern of charges. The panel took the matter under advisement.