In a decision issued today, the Massachusetts Appeals Court for the first time interpreted the state’s newly expanded definition of abuse under the Abuse Prevention Act (G. L. c. 209A). In Kehlani K. v. Tripp T., No. 25-P-960, the court affirmed a District Court judge’s one-year extension of an abuse prevention order, finding that the defendant’s pattern of monitoring and inserting himself into his wife’s life during divorce proceedings constituted “coercive control.”
The parties had been married for 17 years when the wife filed for divorce. Although a probate judge had given her exclusive use of the marital home, the husband allegedly often showed up at the house without permission—sometimes nearly every day—blocking her car, circling the property, and even entering through an unlocked window after the locks were changed. He allegedly photographed her calendar to track her whereabouts, appeared unexpectedly at a child’s soccer game, at school, outside a movie theater in New York, at a vacation rental, and at a hotel, and continued pressing her to call off the divorce. The wife testified that the constant appearances left her fearful he was tracking her and constantly on edge, even at home.
The Legislature added “coercive control” to the definition of abuse effective September 18, 2024. The statute describes it as a pattern of behavior intended to threaten, intimidate, harass, isolate, control, or coerce a family or household member that causes that person to reasonably fear physical harm or have a reduced sense of physical safety or autonomy. Examples include monitoring activities, communications, or movements.
The Appeals Court held that the wife’s testimony established such a pattern: the husband’s repeated monitoring of her activities and movements was intended to pressure her to abandon the divorce, and it reasonably reduced her sense of physical safety and personal autonomy. The court also rejected the husband’s due-process challenge, finding that he had a meaningful opportunity to present evidence and cross-examine the wife despite limits the judge placed on certain follow-up questioning and on reopening the evidence about photographs introduced late in the hearing.
The decision underscores that Massachusetts courts will apply the new coercive-control provision to non-physical but controlling patterns of behavior in the domestic-relations context, particularly where one spouse uses surveillance and unwanted appearances to undermine the other’s independence during a breakup.