A case in which a reporter was held in contempt for refusing to testify to the grand jury was dismissed as moot when the grand jury session expired. See Commonwealth v. Corsetti, 438 N.E.2d 805, 810 (Mass. 1982).
Massachusetts courts will hear appeals of cases when the issue is "capable of repetition but evading review." See, e.g., Cohen v. Bolduc, 760 N.E.2d 714 (Mass. 2002).