Appeals Court Upholds First Coercive Control Order Under Expanded Abuse Definition: Kehlani K. v. Tripp T. (AC 25-P-960, October 22, 2026)

The Massachusetts Appeals Court has affirmed the first reported abuse prevention order based on coercive control under the 2024 amendments to the Abuse Prevention Act. The court held that a husband’s pattern of monitoring his estranged wife, entering her home without permission, and appearing uninvited at locations she frequented constituted coercive control that reduced her sense of physical safety and autonomy.

The Facts

Kehlani K. and Tripp T. had been married for seventeen years. In recent years the plaintiff initiated divorce proceedings. She was “emotionally done,” but the defendant was “not letting go” of the marriage. He told the parties’ three children that the plaintiff, unlike him, did not “want a family.” He told the plaintiff he was “never, ever leaving.” Two days before the hearing he “begged [the plaintiff] to call off the divorce.”

In March 2024, a Probate and Family Court judge granted the plaintiff sole and exclusive use and occupancy of the marital home. The defendant moved out but continued to appear at the home without permission and against the plaintiff’s wishes. He came into her driveway “on a near daily basis,” sometimes blocking her car. The plaintiff’s doorbell camera captured images of him “circling” the house on foot.

The defendant also repeatedly entered the house when the plaintiff was not present, even after she changed the locks. He admitted coming in through an unlocked window on one occasion. Another time he entered without permission and photographed a calendar that provided details of the plaintiff’s whereabouts “at all times.” One of the children was home and photographed the defendant viewing the calendar.

Beyond the home, the defendant sought the plaintiff out in other locations. In late September 2024, he saw her at a soccer game and “continued to harass” her about plans she had made for herself and the children. She was so distressed that she left the game. Shortly after the plaintiff obtained an ex parte abuse prevention order, she arrived at one of the children’s schools to pick up the child and found the defendant waiting there. Although the ex parte order directed him to stay at least 100 yards away, he did not immediately leave when the plaintiff arrived and remained in his car in the parking lot after he left the classroom.

The defendant made so many unexpected appearances that the plaintiff became afraid he was “tracking” her. When she took the children to New York, she arrived at a movie theater to find the defendant waiting outside on a bench. She found him in the backyard of her vacation rental and in a hotel she was staying in “that he wasn’t supposed to gain access to.” These unexplained appearances occurred “for months and months.” The plaintiff testified that the defendant’s conduct made her concerned for her safety and left her acutely vigilant: “I’m here for my safety and for my space and my peace of mind and my health and my stress. So when the [doorbell camera] chime goes off, I don’t jump or I don’t run to the window to see if it’s his car, and nine times out of ten, it is.”

The Statutory Framework

In June 2024, the Legislature expanded the definition of abuse in G.L. c. 209A, § 1, to add “coercive control” as a new category. The statute now defines coercive control as “a pattern of behavior intended to threaten, intimidate, harass, isolate, control, coerce or compel compliance of a family or household member that causes that family or household member to reasonably fear physical harm or have a reduced sense of physical safety or autonomy.”

The definition includes nine nonexclusive examples of qualifying behavior. Among them: isolating the family member from friends or support, depriving them of basic needs, “controlling, regulating or monitoring the family or household member’s activities, communications, movements, finances, economic resources or access to services,” compelling specific behavior, threatening to harm a child or pet, damaging property, threatening to publish sensitive information, or using repeated unwarranted court actions.

The amendments took effect on September 18, 2024. The plaintiff filed her complaint in October 2024. A judge issued an ex parte order and scheduled a hearing after notice. At the hearing, both parties testified. The plaintiff represented herself. The defendant was represented by counsel. The judge ruled that the plaintiff had satisfied her burden and extended the abuse prevention order for one year.

What the Court Held

The Appeals Court affirmed. Writing for a panel that included Judges Massing and Ditkoff, Judge Hand held that the evidence was adequate to prove coercive control under subsection (a)(iii) of the statutory definition, which addresses “controlling, regulating or monitoring the family or household member’s activities, communications, movements, finances, economic resources or access to services.”

The court applied the plain meaning of “pattern” to mean “a mode of behavior or series of acts that are recognizably consistent.” The plaintiff’s testimony about the defendant’s repeated intrusions into her home and activities amply supported a finding of a pattern. The court reserved for another day the question whether a pattern requires proof of some minimum number of acts.

The nature of the defendant’s behavior satisfied the monitoring element. The judge could credit the plaintiff’s descriptions of the defendant’s repeated efforts to track her whereabouts and activities, including maintaining a presence in and around her home at “all hours of the day” and photographing her daily calendar. This was adequate to establish that the defendant was “monitoring [the plaintiff’s] activities” and “movements.”

The evidence also supported an inference of the defendant’s intent to “coerce or compel compliance” with his insistence that she discontinue the divorce proceedings. The judge could conclude that the defendant used information about the plaintiff’s plans and locations, obtained by monitoring her, to create opportunities to insert himself into her family life and press his demands that she “drop the probate case” and work out the marriage with him. The fact that there was no direct evidence of intent did not matter; the judge could reasonably infer intent from the defendant’s conduct.

The court rejected the defendant’s reliance on Counterman v. Colorado, 600 U.S. 66 (2023), a First Amendment case about threatening communications. The analysis here focused on the defendant’s conduct and did not rely on threatening communications. The court noted that the Supreme Judicial Court has solicited amicus briefs in a pending case regarding whether the coercive control provision is vague and overbroad in violation of the First and Fifth Amendments, but the defendant here did not challenge the statute’s constitutionality.

Reduced Sense of Physical Safety or Autonomy

The statute requires proof that the defendant’s pattern of behavior caused the plaintiff “to reasonably fear physical harm or have a reduced sense of physical safety or autonomy.” The court held that the evidence satisfied both disjunctive alternatives.

As to reduced physical safety, there was evidence that the defendant had broken into the house through a window, circled the home on foot, blocked the plaintiff’s car, and appeared to track her movements. The plaintiff feared the defendant, at least in part, for those reasons. That was enough.

Alternatively, the evidence supported a finding of reduced autonomy. The court interpreted “autonomy” to mean “an individual’s ability to make significant decisions unfettered by concerns that doing so will expose that person to abuse.” The plaintiff’s testimony supported a finding that the defendant’s pattern of monitoring left her “look[ing] over [her] shoulder” at all times and reduced her sense of personal freedom, integrity, and independence, even in her own home.

The word “reasonably” modifies both “fear physical harm” and “have a reduced sense of physical safety or autonomy,” so the plaintiff was required to prove that her perception was reasonable. The Supreme Judicial Court had read a similar reasonableness requirement into the earlier definition of abuse by “fear of imminent serious physical harm” in Iamele, despite the fact that the Legislature had not explicitly included a reasonableness requirement in that section.

In assessing reasonableness, the judge could consider the defendant’s disregard of the probate judge’s order granting the plaintiff sole use and occupancy of the marital home and his unwillingness to comply with the no-contact provision in the ex parte order. The judge could also take into account the virtual certainty that the parties would continue to have contact as parents of three school-aged children. Given these facts, the court was satisfied that the evidence showed the reasonableness of the plaintiff’s reduced sense of either physical safety or autonomy.

The Defendant’s Due Process Argument

The defendant argued that he was denied the opportunity to be heard because the judge limited his counsel’s ability to ask follow-up questions after the judge questioned the defendant directly and concluded the hearing without allowing counsel to question the plaintiff about photographs she introduced during summation. The court assumed without deciding that these claims were not waived and rejected them.

As to the follow-up questions, the defendant’s brief included no record citations to support the argument. Without that support, the argument amounted to no more than a “bald assertion[] of error,” and the court declined to address it.

As to the photographs, the court acknowledged that it would have been better practice for the self-represented plaintiff to have offered them during her testimony. But after careful examination of the record, the court was not persuaded. The photographs merely illustrated the plaintiff’s testimony about the defendant’s unwelcome appearances “at the house, at the beach,” “in [her] car, on vacation,” and “in close proximity to [her].” Defense counsel had extensively cross-examined the plaintiff on these issues earlier in the hearing. The court discerned no abuse of discretion in the judge’s decision not to invite counsel to revisit them.

The defendant’s reliance on Idris I. v. Hazel H., 100 Mass. App. Ct. 784 (2022), was misplaced. Unlike the appellant in Idris I., the defendant here had the opportunity to present his evidence and challenge that of the plaintiff. The judge’s limitations on cross-examination about the photographs did not deprive the defendant of a meaningful opportunity to challenge the plaintiff’s evidence.

Why It Matters

This is the first reported decision interpreting the coercive control amendments to G.L. c. 209A. The court’s analysis will guide trial judges, practitioners, and litigants as they apply the new definition. The decision makes clear that coercive control does not require physical violence or threats of imminent harm. A pattern of monitoring, surveillance, and unwelcome intrusions that reduces a person’s sense of autonomy or physical safety can be enough.

The court’s interpretation of “autonomy” is particularly significant. By defining it to include “an individual’s ability to make significant decisions unfettered by concerns that doing so will expose that person to abuse,” the court recognized that coercive control can constrain a person’s freedom without physical force. The plaintiff’s testimony that she was constantly “looking over her shoulder” and could not find peace even in her own home illustrated that constraint.

The court also left several questions open. It did not decide whether a “pattern” requires some minimum number of acts, though it noted that the criminal harassment statute, G.L. c. 265, § 43A, requires “three or more incidents.” It did not reach the constitutional challenges to the coercive control statute now pending before the Supreme Judicial Court in G.P. vs. S.P., No. SJC-13947. And it assumed without deciding that the reduced sense of autonomy need not be physical, given the protective purpose of c. 209A and the nonexclusive list of examples in the statutory definition.

Practitioners should note the court’s emphasis on the totality of the circumstances and the reasonableness standard. The plaintiff’s fear and reduced autonomy had to be reasonable, and the judge could consider the defendant’s violations of prior court orders and the likelihood of continued contact in assessing that reasonableness. The decision also shows that intent to coerce or compel compliance can be inferred from conduct; direct evidence is not required.

Read the full opinion: Kehlani K. v. Tripp T (AC-25-P-960, October 22, 2026).