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Fitzmaurice v. City of Quincy

2026-08-20

Summary

Holding. The court affirmed the order granting the preliminary injunction and denying the motion to dismiss. The plaintiffs have standing under the ten-taxpayer statute, and they have demonstrated a likelihood of success on the merits that the statues violate Article 3 of the Massachusetts Declaration of Rights.

The city of Quincy commissioned two ten-foot bronze statues of Catholic saints—Saint Michael and Saint Florian—to be placed on the façade of a new public safety building at taxpayer expense. Fifteen city residents and taxpayers challenged the installation, arguing it violated the Massachusetts Constitution's guarantee of equal protection and nonsubordination of religious sects. The superior court judge granted a preliminary injunction preventing installation and denied the city's motion to dismiss. On direct appellate review, the Supreme Judicial Court upheld that decision. The court concluded that the plaintiffs have standing under the ten-taxpayer statute because public funds have already been spent on the statues and additional funds will be required for transport and installation. The court applied the established framework from Colo v. Treasurer & Receiver General, which examines the constitutional text, history, and purposes alongside factors identified in relevant case law to identify improper intermingling of government and religion.

The court found that the plaintiffs demonstrated a likelihood of success on the merits. The statues—large, newly commissioned, standing alone without secular counterbalances, and closely affiliated with Catholic iconography and religious significance—pose a substantial risk of being perceived by the public as government endorsement of a particular religion and subordination of others. Although the saints carry secular meaning for first responders, the record established through expert testimony that the statues' primary effect would be to advance a religious message. The court also found that the statues have already caused significant community divisiveness, with hundreds of residents expressing opposition and interfaith leaders voicing concerns. The public interest favors the preliminary injunction because protecting constitutional rights and preventing unlawful expenditure of public funds outweighs minimal harm to the city, which continues to operate its building successfully without the statues.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Standing of taxpayers under the ten-taxpayer statute to challenge municipal expenditure
  • Constitutionality of displaying religious statues on government property under Massachusetts Declaration of Rights Article 3
  • Whether government promotion of particular religious figures violates prohibitions on subordination of religious sects
  • Proper framework for evaluating establishment clause claims under state constitutional law

Procedural posture

The Superior Court granted the plaintiffs' motion for a preliminary injunction and denied the defendants' motion to dismiss; the Supreme Judicial Court granted the city's application for direct appellate review to address the merits of whether the statues violate the Massachusetts Constitution.

Authorities cited

Opinion

majority opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557-1030; [email protected]

SJC-13877

CLAIRE FITZMAURICE & others1 vs. CITY OF QUINCY & another.2

Norfolk. May 6, 2026. - August 20, 2026.

Present: Budd, C.J., Gaziano, Kafker, Wendlandt, Georges,

Dewar, & Wolohojian, JJ.

Constitutional Law, Establishment of religion. Religion.

Municipal Corporations, Fire department, Police, Mayor.

Fire Fighter. Police. Injunction. Practice, Civil,

Preliminary injunction, Standing, Taxable inhabitants'

action, Motion to dismiss.

Civil action commenced in the Superior Court Department on May 28, 2025.

Motions for a preliminary injunction and to dismiss were heard by William F. Sullivan, J.

The Supreme Judicial Court granted an application for direct appellate review.

1 David Reich, Michael Cotter, Marianne Balsamo, Cynthia Roche-Cotter, Salvatore Balsamo, Jay Tarantino, Conevery Bolton Valencius, Matthew Valencius, Cody Hooks, Kathleen Geraghty, Lucille DiGravio, Sheryl LeClair, and Martha Plotkin.

2 Mayor of Quincy.

2

Joseph C. Davis, of the District of Columbia (Eric C. Rassbach & Andrea R. Butler, of the District of Columbia, & James S. Timmins, City Solicitor, also present) for the defendants.

Jessie J. Rossman (Suzanne Schlossberg & Rachel E. Davidson also present) for the plaintiffs.

The following submitted briefs for amici curiae:

Samuel J. Whiting for Massachusetts Family Institute.

Michael A. Heidler, John Heo, & David S. Carter, of Texas, Justin W. Aimonetti, of the District of Columbia, & Ryan Patrick McLane for National Fraternal Order of Police & another.

Gabriela Forero, Paul R. Johnson, & Frank J. Bailey for Pioneer New England Legal Foundation.

Dwight G. Duncan for Islam and Religious Freedom Action Team & another.

Richard P. Driscoll for National Association of Police Organizations.

Michael C. Gilleran for Quincy Firefighters, Local 92, International Association of Fire Fighters, & others.

Gene C. Schaerr & Joshua J. Prince, of the District of Columbia, & Daniel B. Winslow for Protect the First Foundation.

Robert Kingsley Smith & Therese J. Brown for Synod of Bishops of the Russian Orthodox Church Outside of Russia.

Joshua M. Daniels for American Humanist Association & others.

Isabel M. Marin, of the District of Columbia, Kevin P. Martin, Christopher J.C. Herbert, & Ryan H. Brown for Knights of Columbus.

John A. Meiser & Meredith H. Kessler, of Indiana, & Matthew D. Watts for International Association of Fire Fighters & another.

Brinton Lucas & Elise Kostial, of the District of Columbia, & Andrew E. Lelling for American Legion.

Russell B. Balikian & Abby H. Walters, of the District of Columbia, & Joseph V. Cavanagh, III, for Michael McConnell & another.

Mitchell Kosht for Caitlin Borgmann & others.

KAFKER, J. The mayor of the city of Quincy (city) seeks to

install two ten-foot-tall statues on the façade of the city's

new public safety building at taxpayer expense. One statue

depicts Saint Michael, an archangel with wings, stepping on the

3

head and neck of a demon.3 The other depicts Saint Florian, a

larger-than-life Roman soldier towering above a burning building

and extinguishing the fire with water from a single vessel.

Saint Michael and Saint Florian are recognized as religious

saints by the Catholic Church. They are also important symbolic

figures for police officers and firefighters, respected for the

values of bravery and honor they represent.

The plaintiffs, fifteen residents and taxpayers of the

city, sued the city and the mayor in his official capacity to

prevent the installation of the statues, arguing that the

expenditure of public funds on, and the display of, the statues

violate art. 3 of the Massachusetts Declaration of Rights, as

amended by art. 11 of the Amendments to the Massachusetts

Constitution, which provides: "all religious sects and

denominations . . . shall be equally under the protection of the

law; and no subordination of any one sect or denomination to

another shall ever be established by law." A Superior Court

judge granted the plaintiffs' motion for a preliminary

injunction and denied the city's motion to dismiss. The city

appealed, arguing the plaintiffs lack standing and the statues

are permissible under art. 3.

3 The city's brief refers to "Michael" while the plaintiffs' brief refers to "Saint Michael." The same is true for "Florian." As the city used the term "Saint" before each name in the contract commissioning the statues, we do the same.

4

We conclude that the plaintiffs have standing as taxpayers

under G. L. c. 40, § 53. We further conclude that the

constitutionality of the statues must be evaluated according to

the framework we set out in Colo v. Treasurer & Receiver Gen.,

378 Mass. 550 (1979), a decision that explored and applied the

evolving text, constitutional history, and purposes of art. 3.

That decision further considered, as helpful guidance,

additional factors recognized in Federal and State case law,

particularly the United States Supreme Court's decision in Lemon

v. Kurtzman, 403 U.S. 602 (1971), which reflected the Supreme

Court's establishment clause analysis at the time, to identify

improper intermingling of State and religion. Applying the

comprehensive reasoning of Colo, we conclude that the motion

judge did not abuse his discretion in granting the preliminary

injunction. We therefore affirm.4

4 We acknowledge the amicus briefs submitted by Quincy Firefighters, Local 792, International Association of Fire Fighters, Quincy Police Patrol Officers Association, and Quincy Police Superior Officers Association; National Fraternal Order of Police and Massachusetts Fraternal Order of Police; Islam and Religious Freedom Action Team and Jewish Coalition for Religious Liberty; Massachusetts Family Institute; Knights of Columbus; Pioneer New England Legal Foundation; National Association of Police Organizations; International Association of Fire Fighters and Professional Fire Fighters of Massachusetts; Protect the First Foundation; Synod of Bishops of the Russian Orthodox Church Outside of Russia; American Legion; American Humanist Association, Bend the Arc: A Jewish Partnership for Justice, Council on American-Islamic Relations-Massachusetts, DignityUSA, Dignity Boston, Global Justice Institute of the Metropolitan Community Church, Hindu American Foundation, Jewish Alliance for

5

1. Background. a. Facts. "We summarize the facts, which

have reasonable support in the record." Lieber v. President &

Fellows of Harvard College (No. 2), 488 Mass. 816, 817 (2022),

citing Doe v. Worcester Pub. Sch., 484 Mass. 598, 601 (2020).5

In 2017, the city began planning and constructing a new

public safety headquarters to replace the current police station

and to house the city's emergency operations center, and police,

fire, and information technology department offices. The

building is near the corner of Sea Street and Southern Artery,

two main thoroughfares in the city. It is a large, four-story

building approximately 120,000 square feet in size, which cost

approximately $175 million to acquire the land for, build, and

furnish. Residents go to the now-open building to, among other

things, obtain fire permits or records, file and obtain accident

or police reports, meet with police officers, speak with mental

health counselors, attend community meetings and trainings, or

utilize the prescription drug drop box.

Law and Social Action, Methodist Federation for Social Action, Sadhana Coalition, Society for Humanistic Judaism, and Unitarian Universalist Association; Michael McConnell and John Witte, Jr.; and Caitlin Borgmann, Alan Brownstein, Caroline Mala Corbin, Leslie C. Griffin, B. Jessie Hill, Frank S. Ravitch, Laura S. Underkuffler, and Jay D. Wexler.

5 The motion judge did not conduct an evidentiary hearing.

6

At some point in 2023, the mayor decided to commission two

statues for the façade of the building.6 A July 2023 contract

between the mayor's office and a sculptor in Italy commissioned

two ten-foot-tall "bronze sculptures representing Saint Michael

the Archangel the patron saint of Law Enforcement, and Saint

Florian as a protector of fire fighters and a protector against

fire and burning." The statue of Saint Michael depicts him with

the wings of an angel, bearing a shield and stepping on the head

and neck of a demon. The other statue depicts Saint Florian, a

Roman soldier who lived in the Fourth Century. The statue of

Saint Florian portrays a larger-than-life Roman soldier pouring

water from a pitcher onto a much smaller building. The statues

will be placed about halfway up the front of the prominent new

building. They are the only two statues and, indeed, the sole

adornments or decoration the city seeks to install on the front

of the building.

Saint Michael and Saint Florian have both religious and

secular significance. They are recognized as saints in the

Catholic Church. In Catholicism, Saint Michael is so recognized

as a celestial archangel, the leader of God's heavenly army who

cast the devil, Satan, out of heaven. The sacred scriptures of

6 The parties have agreed that the statues are to be analyzed as a set and not separately.

7

other faith traditions, including Judaism and Islam, also

recognize the archangel Michael as a significant figure.

Saint Florian is canonized and venerated as a saint in the

Catholic Church because "he was martyred for his faith and

because he saved a town from [burning] by praying for divine

intervention." In Catholic doctrine, saints are persons in

heaven who lived heroically virtuous lives, offered their lives

for others, or were martyred for the faith, and thus are worthy

of imitation.

Saint Michael and Saint Florian also have a special

significance to police officers and firefighters as symbols of

virtue, bravery, and valor. For example, a portrait of Saint

Michael is a common tattoo for police officers who have tattoos

related to their work, and some police awards and substance

abuse treatment centers have been named after him. As for Saint

Florian, municipalities across Massachusetts, including Quincy,

use the "Florian Cross" on their fire department badges; a union

hall for firefighters in Massachusetts is called Florian Hall;

International Firefighters' Day is celebrated on May 4, Saint

Florian's feast day in the Christian tradition; and an oftinvoked poem for fallen firefighters invites the deceased to

"[r]est with Saint Florian." Two Quincy first responders attest

in affidavits that the statues represent the values they aspire

to emulate in their professions.

8

By January 2025, the city had spent at least $761,378.75 in

public funds on the statues, which are anticipated to cost

$850,000. Although many aspects of the new building were

discussed at length during several city council meetings, most

councillors and the public only learned of the plan to install

the statues when a local newspaper reported on the commission on

February 8, 2025. One councillor reported that he had

previously been informed of the mayor's plans and stated that he

believes the statues "will bless our first responders," and that

he hopes first responders "might say a little prayer before they

go out on duty."

On February 24, 2025, the city council discussed the

statues at a public meeting for the first time. While five to

ten residents typically attend city council meetings, over two

hundred members of the public attended this meeting. There, the

mayor's chief of staff confirmed that the mayor had not

previously notified the city council of the plan to install the

statues.

Since February 2025, hundreds of city residents and at

least one city councillor have publicly opposed the statues. An

online petition opposing the statues garnered over 1,600

signatures, and nineteen faith leaders from the Quincy

Interfaith Network, belonging to many different faiths, issued a

9

public statement expressing "grave concerns" about the statues.7

Another councillor acknowledged that "the statues [are] clearly

contentious for everyone" and that "a bunch of" constituents

expressed their concerns about the statues to him.

b. Procedural history. On May 28, 2025, fifteen8 city

residents filed a complaint in the Superior Court against the

city and the mayor, seeking a judgment declaring that the

expenditure of public funds and planned installation of the

statues violate art. 3, and preliminary and permanent

injunctions prohibiting the defendants from expending more

public funds on the statues and from installing them. The

plaintiffs submitted declarations describing the religious

attributes of the statues, particularly their significance in

the Catholic religion, and stating that the statues send an

exclusionary and subordinating message to non-Catholics and that

some plaintiffs feel personally alienated and excluded by the

city's proposed installation. The defendants moved to dismiss

7 According to the Quincy Interfaith Network, "[e]recting these statues sends a message that there are insiders and outsiders in this community," because saints play an important role "for many of our Roman Catholic neighbors" but "our diverse city is composed of many people of faith and those who do not identify with any religious tradition."

8 One plaintiff voluntarily dismissed her claim; another has moved out of Quincy and intends to move to dismiss his claim once the Superior Court's stay of the proceedings is lifted. Of the other thirteen plaintiffs, twelve pay property taxes in Quincy.

10

the complaint pursuant to Mass. R. Civ. P. 12 (b) (6), 365 Mass.

754 (1974), arguing that the plaintiffs lack standing and have

failed to state a claim.

After a nonevidentiary hearing, the motion judge granted

the plaintiffs' motion for a preliminary injunction and denied

the defendants' motion to dismiss. The judge concluded that the

plaintiffs had standing, both as a group of more than ten

taxpayers under G. L. c. 40, § 53, and as individuals having

alleged cognizable constitutional injuries. He also concluded

that the plaintiffs had demonstrated a likelihood of success on

the merits under the test articulated in this court's decision

in Colo, 378 Mass. at 558, for art. 3 claims. Since the time of

the motion judge's order, the statues have been in a storage

facility in Randolph.

We allowed the city's application for direct appellate

review to address the merits of the order granting the

preliminary injunction, including whether the city's expenditure

of funds and display of these statues violates art. 3.

2. Discussion. a. Standing. As an initial matter, the

city argues that the plaintiffs lack standing to bring this

action.

We conclude that the plaintiffs have standing under G. L.

c. 40, § 53, known as the "ten-taxpayer statute." The tentaxpayer statute provides that "not less than ten taxable

11

inhabitants" may petition a court to restrain a city from

"expend[ing] money . . . for any purpose or object or in any

manner other than that for" which such city "has the legal and

constitutional right and power to . . . expend money." G. L.

c. 40, § 53. See G. L. c. 40, § 1 ("all laws relative to towns

shall apply to cities"). Taxpayer plaintiffs who are so

qualified are empowered to "act as private attorneys general,

enforcing laws designed to protect the public interest."

Edwards v. Boston, 408 Mass. 643, 646 (1990).

The plaintiffs here satisfy these statutory criteria: they

include twelve Quincy taxpayers who allege that the city has

expended public money to commission, and will expend further

public monies to transport and install, statues depicting

Catholic saints on a government building in violation of art. 3.9

The city's arguments to the contrary are unpersuasive.

Citing Edwards, 408 Mass. at 646, the city first urges that

the ten-taxpayer statute only provides a mechanism for enforcing

so-called "spending statutes" -- that is, statutes enacted with

the purpose of preventing the abuse of public funds. But this

9 Because we conclude that the plaintiffs have standing under G. L. c. 40, § 53, we need not decide whether they also have constitutional standing. See Doe No. 1 v. Secretary of Educ., 479 Mass. 375, 386 (2018) ("A party has standing when it can allege an injury within the area of concern of the . . . constitutional guarantee under which the injurious action has occurred").

12

limitation is belied by both the text and purpose of the

provision and the relevant case law. The ten-taxpayer statute

speaks of restraining the expenditure of funds for "any purpose

or object or in any manner" except where the municipality "has

the legal and constitutional right" to so act (emphases added).

G. L. c. 40, § 53. By the statute's plain terms, then, it

confers standing to challenge not only violations of specific

spending statutes, but also unlawful expenditures such as those

alleged in the instant case. See Hollum v. Contributory

Retirement Appeal Bd., 53 Mass. App. Ct. 220, 224 (2001) ("The

word 'any' is generally used in the sense of 'all' or every' and

its meaning is most comprehensive" [citation omitted]). See

also Colo, 378 Mass. at 554 n.7 (interpreting G. L. c. 29, § 63;

analogous statute applicable to Commonwealth taxpayers "provides

the necessary standing" where plaintiffs challenged

constitutionality of expenditure of public funds to clergy for

legislative prayer). Nor would implying such a limitation

further the statute's purpose of allowing "this court to

determine the legality of an appropriation." Richards v.

Treasurer & Receiver Gen., 319 Mass. 672, 676 (1946). Other

cases construing the ten-taxpayer statute, including Edwards,

have said nothing to the contrary. See, e.g., Edwards, supra at

645-647 (discussing enforcement of "spending statute" under

G. L. c. 40, § 53, where plaintiffs argued city's exercise of

13

option in contract with city service provider violated statute

requiring that certain municipal contracts be awarded by

advertised competitive bidding).

The city also asserts that the plaintiffs lack standing

because they have not shown that their tax burden will increase

if the statues are installed. The statues have already cost

$761,378.75 in public funds. Additional moneys will be required

to transport the statues from storage and affix them to the

public safety building's façade.10 For these reasons, the tentaxpayer statute confers standing on the plaintiffs to enjoin

further expenditure and installation of the statues. See G. L.

c. 40, § 53.11

10We also note that this is not a case where such costs will be reimbursed. See, e.g., Howard v. Chicopee, 299 Mass. 115, 120 (1938) ("the entire cost of labor and materials furnished by Chicopee in connection with such installation has been paid to Chicopee by the Holyoke company," and therefore, "the petitions have no ground for relief under [G. L. c. 40, § 53]").

11Although the anticipated transportation and installation costs are sufficient to confer standing under the ten-taxpayer statute in this case, as noted by the motion judge and discussed further infra, undisputed facts in the record demonstrate that public funds were expended to commission the statues several years before the mayor's plans were in any way made public. As we have previously emphasized, "no surreptitious attempt to outwit the [ten-taxpayer] statute . . . can be tolerated, and under such circumstances relief would be afforded" even after an illegal payment has already been made. Fuller v. Trustees of Deerfield Academy, 252 Mass. 258, 260 (1925).

14

b. Grant of preliminary injunction. "We review the grant

or denial of a preliminary injunction to determine whether the

[motion] judge abused his discretion, that is, whether the judge

applied proper legal standards and whether there was reasonable

support for his evaluation of factual questions." Doe v.

Superintendent of Sch. of Weston, 461 Mass. 159, 164 (2011),

quoting Commonwealth v. Fremont Inv. & Loan, 452 Mass. 733, 741

(2008). Furthermore, "[w]here, as here, no evidentiary hearing

was held and the record consists of affidavits and other

documents, although 'weight will be accorded to the exercise of

discretion by the judge below, . . . we may draw our own

conclusions from the record.'" Lieber, 488 Mass. at 821,

quoting Packaging Indus. Group, Inc. v. Cheney, 380 Mass. 609,

616 (1980). Finally, as this is a ten-taxpayer statute case,

"[i]n order to obtain a preliminary injunction, the plaintiffs

must show a likelihood of success on the merits and that the

requested relief would be in the public interest; they need not

demonstrate irreparable harm." Caplan v. Acton, 479 Mass. 69,

75 (2018).

The city argues that the judge erred in granting the

plaintiffs' motion for a preliminary injunction because the

plaintiffs have not satisfied the first preliminary injunction

factor by showing that expenditure of further funds and

installing the statues likely violates art. 3. Before turning

15

to the facts of this case, we begin by describing the text,

history, and purpose of art. 3 and the legal standards we have

articulated for evaluating claims brought under this

constitutional provision.

i. Article 3 and the Colo standards. Article 3, adopted

in 1780, originally stated,

"[T]he legislature shall, from time to time, authorize and

require, the several towns, parishes, precincts, and other

bodies politic, or religious societies, to make suitable

provision, at their own expense, for the institution of the

public worship of GOD, and for support and maintenance of

public Protestant teachers of piety, religion, and morality

. . . ."

Colo, 378 Mass. at 556 n.10. As we have previously explained,

"[b]ecause Congregationalists were the overwhelming majority of

the population in Massachusetts at the time, art. 3 functioned

as a de facto general assessment in favor of the Congregational

Church." Caplan, 479 Mass. at 76 n.7.

In 1833, "[a]fter decades of 'lawsuits, bad feeling, and

petty persecution,'" art. 3 was amended. Caplan, 479 Mass. at

76, quoting S.E. Morison, A History of the Constitution of

Massachusetts 24 (1917). As amended, art. 3 now provides, in

relevant part, that "all religious sects and denominations,

demeaning themselves peaceably, and as good citizens of the

[C]ommonwealth, shall be equally under the protection of the

law; and no subordination of any one sect or denomination to

another shall ever be established by law."

16

We established a framework for evaluating claims under

art. 3 in Colo, 378 Mass. 550. In that case, taxpayers

challenged the use of public money to pay the salaries of the

chaplains of the Massachusetts House of Representatives and

Senate, as a violation of, inter alia, art. 3 and the First

Amendment to the United States Constitution. Id. at 551-552.

The chaplains were both Catholic priests who opened the daily

legislative sessions of their respective chambers with a

voluntary prayer. Id. at 551.12

The court emphasized that "[t]here are no simple tests or

precise lines by which we can determine the constitutionality of

the challenged payments." Id. at 554. Instead, in determining

whether art. 3 is violated, the court stated, "we must view the

purposes and history of the practice in relation to the purposes

and history of the governing constitutional amendments, and in

the light of what can be gleaned from decisions on somewhat

similar practices by other State and Federal courts" (footnote

12 The court noted, however,

"The mere fact that two persons of a particular faith have

been appointed to these positions for over the past twenty

years does not demonstrate that any other person has ever

been denied appointment (a necessary element of any equal

protection claim), or that such decisions were based on

religious discrimination."

Colo, 378 Mass. at 557.

17

omitted). Id. The court further explained that this is a

complex task because a review of the history and purposes of the

relevant constitutional clauses, as well as the case law,

demonstrates that "[i]t has never been thought either possible

or desirable to enforce a regime of total separation [between

church and State]," thereby making line drawing between

permissible and prohibited intermingling of church and State

difficult to discern.13 Id., quoting Committee for Pub. Educ.

& Religious Liberty v. Nyquist, 413 U.S. 756, 760 (1973).

The court's historical analysis in Colo is also informative

and nuanced. The court put the contested practice --legislative chaplains -- into historical context, explaining

that legislative chaplains reflected a long-standing practice

and tradition: legislative chaplains performed this role at the

time of the passage of the First Amendment, without objection.

13As the Colo court concluded, "the 'hermetic separation' of church and State is an impossibility which the Constitution has never required. . . . The complete obliteration of all vestiges of religious tradition from our public life is unnecessary to carry out the goals of nonestablishment and religious freedom . . ." (citations omitted). Colo, 378 Mass. at 560-561. See Kent v. Commissioner of Educ., 380 Mass. 235, 245 (1980) ("This court has recognized the unwisdom, as well as the futility, of trying to separate Church from State by an impenetrable barrier").

18

Id. at 555-556.14 The same was true in Massachusetts at the time

of the passage of the Declaration of Rights. Id. at 556.

The court's historical analysis in Colo further examined

the evolution of Massachusetts constitutional provisions, and

how the contested practice continued throughout that evolution.15

The court recounted how Massachusetts moved from public support

of the Christian religion to equal protection and

nonsubordination of all religious sects and denominations. Id.

The court also discussed how the "appropriation of public funds

for religious purposes was debated at the Constitutional

Convention of 1917-1918, when various amendments were proposed

14The court noted James Madison nonetheless had private concerns regarding the practice. Colo, 378 Mass. at 555-557 & nn.9, 12.

15 The court also discussed societal change more generally:

"[T]he degree of intermingling of religious and secular

life was much greater at the time the First Amendment was

being debated than it is today. Most of the original

States, including Massachusetts, had established churches

supported directly by tax dollars, and there was often

little tolerance for dissenting religious views. The

drafters and ratifiers of the First Amendment designed it

to address far more pervasive threats to religious liberty

and the separation of church and State than any that exist

today."

Colo, 378 Mass. at 555.

19

[and passed] to prohibit public funding of parochial schools."

Id.16

The court then explained how the contested practice of

legislative chaplains continued, without opposition, even as the

constitutional provisions themselves evolved and tightened the

restrictions against public support or public preferences for

particular religions:

"Throughout this history of often vigorous debate about the

proper relationship between church and State, the

appointment and payment of legislative chaplains continued

without apparent dissension. As one delegate (John W.

McAnarney of Quincy) to the 1917-1918 Constitutional

Convention remarked, the sentiment which led to the

convention's approval of an 'anti-aid amendment' was not

that 'the State is opposed to religion, . . . [we] bear

testimony to that every morning in this Convention, sir,

when we have the divine aid and assistance invoked to guide

us in our deliberations." (Footnote omitted.)

We have characterized the purposes of art. 18 of the

16

Amendments to the Massachusetts Constitution, as amended by arts. 46 and 103 of the Amendments, known as the "anti-aid amendment," as follows:

"Proponents of [the anti-aid amendment] urged that liberty

of conscience was infringed whenever a citizen was taxed to

support the religious institutions of others; that the

churches would benefit in independence and dignity by not

relying on governmental support; and, more generally or

colloquially, that to promote civic harmony the irritating

question of religion should be removed from politics as far

as possible, and with it the unseemly and potentially

dangerous scramble of religious institutions for public

funds in ever-increasing amounts."

Bloom v. School Comm. of Springfield, 376 Mass. 35, 39 (1978), citing 1 Debates in the Massachusetts Constitutional Convention 1917-1918, at 68, 74-79, 161-164 (1919). See Caplan, 479 Mass. at 80-81.

20

Id. at 556, quoting 1 Debates in the Massachusetts

Constitutional Convention 1917-1918, at 190 (1919).

Although the court considered this history important, its

analysis did not conclude there. Instead, the court held that

"the mere fact that a certain practice has gone

unchallenged for a long period of time cannot alone

immunize it from constitutional invalidity, 'even when that

span of time covers our entire national existence and

indeed predates it.' Walz v. Tax Comm'n of the City of

N.Y., 397 U.S. 664, 678 (1970). The long history of a

certain practice, however, and its acceptance as an

uncontroversial part of our national and State tradition do

suggest that we should reflect carefully before striking it

down."

Colo, 378 Mass. at 557.

In addition to looking at the relevant constitutional text,

purposes, and history, the court was also "aided by" the

criteria considered by other State and Federal courts,

particularly those articulated by the United States Supreme

Court in Lemon, 403 U.S. 602, which, at the time, were used to

evaluate anti-establishment claims under the First Amendment:

"(1) [I]s there a 'secular legislative purpose,' (2) does the

primary effect of the challenged practice 'neither advance nor

inhibit religion,' and (3) is there avoidance of 'excessive

government entanglement' with religion?" Colo, 378 Mass. at

558, quoting Lemon, supra at 612-613. The court also noted a

"significant fourth factor," not expressly identified in Lemon,

"that is, whether the challenged practice has a 'divisive

21

political potential.'" Colo, supra, quoting Meek v. Pittenger,

421 U.S. 349, 374 (1975) (Brennan, J., concurring in part and

dissenting in part). The court, however, repeatedly emphasized

that these criteria were not to be considered as "mechanistic

tests" or "precise limits to the necessary constitutional

inquiry," but rather helpful "guidelines to analysis" that were

"equally appropriate to claims brought under cognate provisions

of the Massachusetts constitution" (quotation omitted). Colo,

supra.17

Applying these guidelines along with the constitutional

text and history, the court in Colo ultimately upheld the

employment of legislative chaplains based on the long-standing

history and acceptance of opening prayers; the secular purposes

of the tradition to "prompt[] legislators to reflect on the

gravity and solemnity of their responsibilities"; the primary

effect, which the court concluded was not to advance religion

but to reflect this gravity and solemnity of the occasion of the

17As this court cannot provide less protection against the establishment of religion under art. 3 than the Supreme Court allows under the establishment clause of the First Amendment, consideration of the Supreme Court's relevant anti-establishment test at the time was a necessary part of the court's analysis in Colo, where the court was not concluding the conduct in question was protected by art. 3. Cf. Commonwealth v. DeJesus, 489 Mass. 292, 296 (2022) ("the Massachusetts Constitution may not provide less protection to defendants than the Federal Constitution); Commonwealth v. Robinson, 480 Mass. 146, 147 n.3 (2018), S.C., 493 Mass. 303 (2024) (same).

22

opening of the legislative session; the brief duration and the

voluntary nature of the prayer; and the absence of evidence that

the practice caused any divisiveness. Id. at 554, 559-560.

We recognize that the Supreme Court has since abandoned

Lemon and substituted in its place an analysis by "reference to

historical practices and understandings." Kennedy v. Bremerton

Sch. Dist., 597 U.S. 507, 534-535 (2022), quoting Greece, N.Y.

v. Galloway, 572 U.S. 565, 576 (2014). The city urges us, as a

result, to reject "the Lemon test" as a matter of Massachusetts

constitutional law. But the Colo framework, as explained above,

is neither limited to, nor dependent upon, a "mechanistic"

application of the Lemon factors. Importantly, our analysis in

Colo began with a careful and nuanced examination of the

purposes and history of both the challenged practice and the

relevant constitutional amendments. It also recognized that the

text, purpose, and history of art. 3 have evolved over time,

reflecting societal changes as well. See generally Kligler v.

Attorney Gen., 491 Mass. 38, 58 (2022), quoting Obergefell v.

Hodges, 576 U.S. 644, 664 (2015) ("History and tradition guide

and discipline [the] inquiry but do not set its outer

boundaries. . . . That method respects our history and learns

from it without allowing the past alone to rule the present").

Only then did we in Colo turn to the Lemon factors, as well as

an evaluation of the potential for divisiveness resulting from

23

the contested practice, for additional guidance. The Colo

framework therefore properly focuses on constitutional text,

history, purpose, and factors the case law has long recognized

as helpful in identifying improper intermingling of State and

religion. This comprehensive framework, including consideration

of the purposes of the contested practice, its primary effects,

and its potential for divisiveness, has also been consistently

utilized by this court, including in its enforcement of the

anti-aid provisions of our State Constitution. See, e.g.,

Caplan, 479 Mass. at 82-83. For all these reasons, we conclude

that Colo remains good law and the proper framework for

evaluation of contested practices under art. 3.18

18We further note the importance of stare decisis. Although stare decisis is not "a universal, inexorable command," Burnet v. Coronado Oil & Gas Co., 285 U.S. 393, 405 (1932) (Brandeis, J., dissenting), "adhering to precedent is our 'preferred course because it promotes the evenhanded, predictable, and consistent development of legal principles, fosters reliance on judicial decisions, and contributes to the actual and perceived integrity of the judicial process,'" Shiel v. Rowell, 480 Mass. 106, 108 (2018), quoting Payne v. Tennessee, 501 U.S. 808, 827 (1991). See Johnson v. Settino, 495 Mass. 42, 51 (2024), quoting Franklin v. Albert, 381 Mass. 611, 617 (1980) ("We depart from precedent where 'the values in so doing outweigh the values underlying stare decisis'").

As for the Lemon factors themselves, we may of course continue to consider critical commentary from the Supreme Court and elsewhere in determining just how helpful those factors actually are in identifying improper intermingling under art. 3. See, e.g., Kennedy, 597 U.S. at 534, quoting Capitol Sq. Review & Advisory Bd. v. Pinette, 515 U.S. 753, 768 n.3 (1995) (plurality opinion) (stating that application of Lemon has "'invited chaos' in lower courts, led to 'differing results' in

24

ii. Likelihood of success on the merits. Accordingly, we

assess the plaintiffs' likelihood of success on the merits under

the Colo framework described above. We begin with the text,

purposes, and history of art. 3. As the Colo court explained,

art. 3 originally gave preference to a particular religious sect

and was amended to abolish such a preference and to provide for

equal protection and nonsubordination of other sects and

denominations.

The contested practice here raises concerns at the core of

the text, purposes, and history of the amendment of art. 3:

whether the city is singling out a particular religion for

special treatment.19 See Catholic Charities Bur., Inc. v.

Wisconsin Labor & Indus. Review Comm'n, 605 U.S. 238, 248 (2025)

materially identical cases, and created a 'minefield' for legislators"). Finally, we recognize that the Supreme Court is no longer employing these factors in its own anti-establishment jurisprudence under the First Amendment, so we must consider the Supreme Court's more recent precedent, and not its previous application of the Lemon test, when we determine whether we are providing at least as much protection against the establishment of religion as the Supreme Court, as we are required to do by the Federal Constitution. See note 17, supra.

19 The motion judge determined:

"The depiction of the statues, their association with one

religion, and the various reactions of community members,

City Council members, and faith leaders demonstrate

Plaintiffs will likely be able to show that the statues

convey to the public observing them the implicit government

support for the religious doctrine and adherents of

Catholic/Christian faith, and as a result, the

subordination of other religions."

25

("the 'fullest realization of true religious liberty requires

that government' refrain from 'favoritism among sects'"

[citation omitted]); Van Orden v. Perry, 545 U.S. 677, 698

(2005) (Breyer, J., concurring), quoting School Dist. of

Abington Township, Pa. v. Schempp, 374 U.S. 203, 305 (1963)

(Goldberg, J., concurring) ("The Court has made clear, as

Justices Goldberg and Harlan noted, . . . that government must

. . . 'effect no favoritism among sects or between religion and

nonreligion' . . ."). See also County of Allegheny v. American

Civ. Liberties Union, Greater Pittsburgh Chapter, 492 U.S. 573,

590 (1989) (County of Allegheny) ("In the course of adjudicating

specific cases, this Court has come to understand the

[e]stablishment [c]lause to mean that government may not promote

or affiliate itself with any religious doctrine or organization

. . ."). The two statues are both of Catholic saints. They are

each ten feet tall, and they will be prominently placed on the

front of the city's public safety building facing a busy street.

The plaintiffs' unrebutted expert attested that "patron saints

are particular to Catholicism"; the depictions of Saint Michael

and Saint Florian in these statues "are consistent with

iconography of each religious figure within Catholic tradition";

and the symbols and objects depicted "are all central to the

iconographies of each saint, which are not intelligible without

reference to Catholic tradition." Indeed, one is an archangel

26

with wings, and the other is portrayed as performing one of the

miracles for which he is venerated by the Catholic Church.

The likelihood that these statues of religious figures

closely associated with the Catholic faith could be viewed by

the public as endorsement of a particular religion, and thus

subordination of others, is enhanced by the fact that the

statues are not part of a larger collection of statues and

monuments that includes nonreligious ones, or statues of figures

of particular importance to other religions. Contrast Van

Orden, 545 U.S. at 681, 691 (plurality opinion) (Ten

Commandments monument situated among seventeen monuments and

twenty-one historical markers commemorating Texan identity did

not violate establishment clause); County of Allegheny, 492 U.S.

at 620 (Blackmun, J.) ("it is not sufficiently likely that

residents of Pittsburgh will perceive the combined display of

the [Christmas] tree, the [explanatory] sign [describing the

holiday season and winter festivals], and the menorah as an

endorsement or disapproval . . . of their individual religious

choices" [quotations and citation omitted]); Lynch v. Donnelly,

465 U.S. 668, 679-683 (1984) (crèche in city's annual holiday

display had permissible purpose and effect when accompanied by

secular symbols and considered "in the context of the Christmas

season"); American Atheists, Inc. v. Port Auth. of N.Y. & N.J.,

760 F.3d 227, 240, 242-244 (2d Cir. 2014) (Christian cross

27

displayed in museum at site of September 11 attack had

permissible purpose and effect where situated amidst secular

artifacts and textual panel explained its historical

significance).20 Rather, they stand tall and alone, adorned with

Catholic iconography. See County of Allegheny, supra at 598

(single crèche as primary element of display in government

building demonstrated government endorsement of religious

message).

These statues are also not long-standing historic monuments

important to our common history, unlike many of the examples

highlighted by the city. They are unlike, for example, a

Nineteenth Century statue in Plymouth honoring the Mayflower

passengers fleeing religious persecution, featuring a woman

clutching a Bible, and cross-shaped grave markers of soldiers

20The statue of Moses in the Great Hall of the John Adams Courthouse, for example, is one of sixteen allegorical statues representing not only "Religion," but also virtues and concepts such as "Law," "Justice," and "Reason"; such installations are "part of a continuing tradition that started in antiquity." Bresler, Virtues in the Great Hall: Understanding the Allegorical Statues in the John Adams Courthouse, 102 Mass. L. Rev. 71, 71, 81 (2021). A marble frieze of Moses in the Supreme Court building is similarly included in a series of great lawgivers of history. See id. at 81-82. See also County of Allegheny, 492 U.S. at 652-653 & n.13 (Stevens, J., concurring in part) ("Placement of secular figures such as Caesar Augustus, William Blackstone, Napoleon Bonaparte, and John Marshall alongside [Moses, Confucius, and Mohammed], however, signals respect not for great proselytizers but for great

lawgivers. . . . All these leaders, of course, appear in friezes on the walls of our courtroom").

28

who died for our country in the World Wars, monuments with

obvious religious origins but ones that have also taken on a

common, secular meaning and significance over time. See

American Legion v. American Humanist Ass'n, 588 U.S. 29, 38

(2019) ("For nearly a century, the Bladensburg Cross has

expressed the community's grief at the loss of the young men who

perished, its thanks for their sacrifice, and its dedication to

the ideals for which they fought"). As the Supreme Court has

explained, removal of such historic monuments presents a

different set of issues. See id. at 56-57; Colo, 378 Mass. at

557. Here, by contrast, without such secular meaning built

through common history, these new statues have a greater

potential to be perceived as government endorsement of a

particular religion, and subordination of other religions, in

violation of art. 3.

In sum, the preliminary injunction record reflects that the

statues are large and will stand alone, they are brand new

rather than long standing, they are closely affiliated with a

particular religion, and they thus may convey to observing

members of the public implicit government support for that

religion and, as a result, subordination of other religions.

All of this supports the motion judge's conclusion that the

plaintiffs have a likelihood of success on the merits.

29

We also discern no abuse of discretion in the motion

judge's evaluation of the likelihood of success even if the

statues serve secular as well as religious purposes. See

Caplan, 479 Mass. at 87 n.22 ("whether an impermissible purpose

is the sole motivating purpose behind the [government action],

or only one purpose among many, may be considered in determining

the weight to accord that factor"); Colo, 378 Mass. at 559

(discussing both secular and religious aspects of opening

invocations). We recognize that there is evidence in the record

-- for example, the presence of the Florian Cross on fire

department badges and the naming of Florian Hall, as well as the

naming of certain police awards after Saint Michael -- that

these saints are important symbols of courage, virtue, and valor

for first responders, including first responders of different

faiths and those without religious faith. The affidavits of the

Quincy first responders credibly support the secular

significance of these symbols.21 The record before the motion

judge, however, also demonstrates that these symbols have

distinctly Catholic roots and references, as explained by the

plaintiffs' unrebutted expert. As the motion judge found, the

21If this litigation proceeds, the evidence regarding the secular significance of Saint Michael and Saint Florian, including in particular whether this secular significance would be understood by members of the public, may of course be further developed.

30

statue of Saint Michael "is overtly religious, displaying large

wings of an archangel and standing on a demon representative of

Satan," and would be so understood by an objective observer.

The message conveyed by Saint Florian's statue is also difficult

to discern without an explanation of its historic and religious

origins. On this record, the motion judge's conclusion that the

statues' primary effect will be to advance a religious message

therefore does not constitute an abuse of discretion. See

Society of Jesus of New England v. Commonwealth, 441 Mass. 662,

674, S.C., 442 Mass. 1049 (2004) ("With regard to the test of

'effect' on religion, we must look at the law's 'principal or

primary effect' . . ." [citation omitted]). There is reasonable

factual support in the record for his conclusion, even if there

is evidence of a secular as well as a religious purpose to the

statues.22

22In so concluding, we discern no abuse of discretion by the motion judge in rejecting the mayor's affidavit. Here, the motion judge was "not persuaded by the Mayor's self-serving assertions [of only a secular purpose], particularly in light of his curious actions of commissioning the statues without public knowledge." As the Supreme Court has explained, "[w]hen a governmental entity professes a secular purpose for an arguably religious policy, the government's characterization is, of course, entitled to some deference. But it is nonetheless the duty of the courts to distinguish a sham secular purpose from a sincere one" (quotation, citation, and alteration omitted). Santa Fe Indep. Sch. Dist. v. Doe, 530 U.S. 290, 308 (2000). See McCreary County, Ky. v. American Civ. Liberties Union of Ky., 545 U.S. 844, 864 (2005) ("although a legislature's stated reasons will generally get deference, the secular purpose required has to be genuine, not a sham, and not merely secondary

31

There is also reasonable support in the record for the

motion judge's determination that the statues have caused

divisiveness. More than two hundred people attended the first

city council meeting after the plan for the statues was publicly

revealed, as opposed to the usual five to ten attendees. Since

then, hundreds of residents have publicly expressed opposition

to the statues; one city councillor has described how

contentious the statues are for his constituents; an online

petition opposing the statues garnered over 1,600 signatures;

and faith leaders from the Quincy Interfaith Network issued a

public statement expressing "grave concerns" about the statues.23

Finally, the city, without supporting analysis, also

contends that prohibiting the statues under art. 3 would violate

to a religious objective"). Based on the abbreviated record before the motion judge, the judge could reject the affidavit for the reasons stated. See Hull Mun. Lighting Plant v. Massachusetts Mun. Wholesale Elec. Co., 399 Mass. 640, 645 (1987) ("a preliminary injunction, by definition, must be granted or denied after an abbreviated presentation of facts and the law"). Of course, if this litigation continues, the mayor, as the person solely responsible for the selection of the statues, will be subject to further inquiry, including the "crucible of cross-examination," to determine whether he selected the statues for secular purposes as he contended in his affidavit, or to impress and impose his own religious beliefs on the city, or for a combination of both purposes. Commonwealth v. DeOliviera, 447 Mass. 56, 57 (2006), quoting Crawford v. Washington, 541 U.S. 36, 61 (2004).

23It is less clear, and we need not decide, whether the record reasonably supports the motion judge's determination that installing the statues will foster excessive government entanglement with religion.

32

the United States Constitution because it amounts to hostility

to religion. The Supreme Court has emphasized that

"the government, if it is to respect the Constitution's

guarantee of free exercise, cannot impose regulations that are

hostile to the religious beliefs of affected citizens . . . .

The [f]ree [e]xercise [c]lause bars even subtle departures from

neutrality on matters of religion" (quotation and citation

omitted). Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights

Comm'n, 584 U.S. 617, 638 (2018). The instant case, however,

presents no free exercise claim. The city itself has no free

exercise rights, under either the State or the Federal

Constitution, as the free exercise clauses protect private

religious expression -- not the government's -- from government

interference. See First Amendment to the United States

Constitution; Kennedy, 597 U.S. at 529. We also agree that

"hostility toward religion . . . has no place in our

[e]stablishment [c]lause traditions." American Legion, 588 U.S.

at 38, quoting Van Orden, 545 U.S. at 704 (Breyer, J.,

concurring). On this record, however, as the motion judge

determined, the issue presented is not government hostility to

religion but government preferential treatment of a particular

religion.

For all these reasons, we conclude that the judge did not

abuse his discretion in evaluating the likelihood of success.

33

iii. The public interest. The other factor in determining

whether the plaintiffs are entitled to the preliminary

injunction -- the public interest -- weighs strongly in favor of

the plaintiffs. As the motion judge determined, the plaintiffs

have demonstrated a reasonable likelihood that the city has

violated important constitutional rights and has spent, and

plans to continue to spend, taxpayer dollars in violation of

those rights that will not be recoverable. Furthermore, as the

motion judge determined and as the plaintiffs' declarations in

the record supported, were the statues to be installed for the

duration of this litigation, the plaintiffs and other members of

the public would have to confront them regularly, experiencing

feelings of subordination given their own religious beliefs or

nonbeliefs.

In contrast, as the motion judge also determined, the

potential harm to the city is minimal. The building is open and

functioning without the statues. Contrast LeClair v. Norwell,

430 Mass. 328, 339 (1999) ("By delaying the design services

contract, the town will likely be excluded from the priority

list for State funding for school construction. If an

injunction were entered, the town would lose or delay receipt of

substantial grant funding, thereby potentially delaying school

construction and increasing design and construction costs").

The statues are safely in storage pending the outcome of the

34

litigation. This is therefore not a case where a preliminary

injunction interferes with the government's interest in any

meaningful way.

In sum, the public interest weighs heavily in favor of the

preliminary injunction.

3. Conclusion. Because the plaintiffs have demonstrated a

likelihood of success on the merits to show that the statues

violate art. 3, and the public interest weighs in the

plaintiffs' favor, the order granting the plaintiffs' motion for

a preliminary injunction and denying the defendants' motion to

dismiss is affirmed.

So ordered.