A restraining order case from Dedham District Court has produced the first published Massachusetts Appeals Court decision interpreting the state’s 2024 coercive-control provisions.
In Kehlani K. v. Tripp T., decided Oct. 22, the court upheld a one-year abuse prevention order based on a husband’s repeated monitoring, unauthorized home entries and unwanted appearances during divorce proceedings. The parties’ names are court-assigned pseudonyms.
The ruling provides guidance on when conduct without physical violence can support a restraining order under Chapter 209A. Massachusetts added coercive control to the statute effective Sept. 18, 2024.
The law recognizes a pattern intended to intimidate, harass, isolate, control or compel a family or household member’s compliance when it reasonably reduces that person’s sense of safety or autonomy. Certain specified single acts can also qualify under a separate provision. The statute lists monitoring someone’s movements among its examples.
According to evidence credited by the trial judge, the husband continued appearing at the marital home after his wife received exclusive occupancy. He sometimes blocked her car, entered without permission and photographed a calendar detailing her whereabouts.
The wife also described unexpected encounters away from home that left her worried he was tracking her. Judge Paul J. McCallum extended the order after both parties testified.
The Appeals Court found sufficient evidence of a consistent pattern intended to pressure her to abandon the divorce. Intent could be inferred from conduct. The court also emphasized that her reduced sense of safety or autonomy had to be reasonable under the circumstances. Appeals Court decision
The husband did not challenge the statute’s constitutionality. The opinion noted that the Supreme Judicial Court had requested briefing on vagueness and overbreadth questions in a separate case, G.P. v. S.P.
People affected by domestic abuse can contact SafeLink, Massachusetts’ statewide hotline, at 877-785-2020. DOVE, which serves Dedham, operates a crisis hotline at 617-471-1234.
