Coercive Control Is Domestic Abuse: Massachusetts Appeals Court Upholds Restraining Order Under New Law

Domestic abuse does not always leave a bruise. Sometimes, it looks like constant surveillance, unwanted appearances, intimidation, or a relentless effort to control another person’s decisions.

In a significant decision issued on October 22, 2026, the Massachusetts Appeals Court affirmed a restraining order based on coercive control, reinforcing an important expansion of legal protections for survivors of domestic abuse. 

In Kehlani K. v. Tripp T., No. 25-P-960 (Mass. App. Ct. Oct. 22, 2026), the Appeals Court interpreted and applied Massachusetts’ relatively new coercive control law for the first time, recognizing that a pattern of controlling behavior can constitute abuse even without allegations of physical violence or explicit threats of bodily harm. 

The decision represents an important development in Massachusetts family law and reinforces a fundamental principle: Abuse is not limited to physical violence. The systematic destruction of another person’s sense of safety, independence, and autonomy can be equally deserving of legal protection. 

Massachusetts Expands Its Definition of Domestic Abuse

For decades, Massachusetts General Laws Chapter 209A, commonly known as the Abuse Prevention Act, provided protection against domestic abuse based on three primary categories of conduct: 

• Attempting to cause or causing physical harm; 

• Placing another person in fear of imminent serious physical harm; or 

• Causing another person to engage involuntarily in sexual relations through force, threats, or duress. 

While these protections remain essential, they did not always adequately address the realities of abusive relationships in which one partner exercised control through intimidation, surveillance, isolation, financial manipulation, or other nonphysical means. 

Recognizing this gap, the Massachusetts Legislature amended Chapter 209A in 2024 to expressly include coercive control within the definition of abuse. The amendment became effective September 18, 2024. 

Under the amended statute, coercive control includes a pattern of behavior intended to threaten, intimidate, harass, isolate, control, coerce, or compel compliance by a family or household member, causing that person to reasonably fear physical harm or experience a reduced sense of physical safety or autonomy. 

The statute identifies several examples of potentially abusive conduct, including monitoring someone’s movements or communications, restricting access to finances, isolating someone from friends and family, threatening children or pets, and using certain repeated, legally unwarranted court proceedings as a means of control. 

Importantly, the statute recognizes that abuse can be cumulative. Conduct that might appear relatively innocuous when viewed in isolation can become deeply threatening when it forms part of a sustained pattern of intimidation and control. 

The Case: A Husband Who Would Not Accept the End of His Marriage

In Kehlani K. v. Tripp T., the parties had been married for approximately seventeen years and were involved in divorce proceedings initiated by the wife. 

Although the wife had decided to end the marriage, the husband repeatedly resisted her decision and continued attempting to insert himself into her daily life. 

A Probate and Family Court judge had already awarded the wife exclusive use and occupancy of the marital home. Nevertheless, the husband continued appearing at the property without permission, sometimes nearly every day. 

According to testimony credited by the trial court, his conduct included: 

• Repeatedly appearing at the marital home without permission, including entering the property after the wife changed the locks; 

• Entering the house through an unlocked window; 

• Photographing the wife’s personal calendar, which contained information about her whereabouts; 

• Circling the home on foot and occasionally blocking her vehicle in the driveway; 

• Appearing unexpectedly at locations where the wife was present, including children’s activities, vacation accommodations, and a movie theater in another state; and 

• Repeatedly pressuring the wife to abandon the divorce proceedings and reconcile. 

The wife testified that the husband’s repeated appearances caused her to feel constantly watched and fearful about where he might appear next. 

She described living in a state of heightened vigilance, checking her surroundings and reacting anxiously whenever her doorbell camera alerted her to activity outside her home. 

The District Court issued an abuse prevention order and subsequently extended it for one year. The husband appealed, arguing, among other things, that the evidence was insufficient to establish abuse under the new coercive control provision. 

The Massachusetts Appeals Court disagreed and affirmed the restraining order. 

Why the Appeals Court’s Decision Matters

The Appeals Court’s decision is particularly important because it provides meaningful guidance about how Massachusetts courts should evaluate coercive control claims. 

 

The Court identified several key considerations. 

1. Courts Must Examine the Pattern, Not Just Individual Incidents

One of the most significant aspects of coercive control is that abusive conduct often develops over time. 

A single unexpected appearance at a child’s sporting event might not constitute abuse. However, repeated appearances at someone’s home, workplace, vacation destination, or other locations, particularly after being told to stay away, may reveal a deliberate pattern of monitoring and intimidation. 

The Appeals Court recognized that the husband’s repeated intrusions into the wife’s home and activities established a recognizable pattern of behavior. 

This distinction is critical because individuals experiencing coercive control often struggle to explain why a series of seemingly minor incidents leaves them feeling unsafe. 

The law now expressly allows courts to examine the larger pattern of behavior rather than requiring each incident to independently establish traditional forms of abuse. 

2. Intent to Control Can Be Inferred From Conduct

The Court also addressed whether the husband intended to coerce or compel the wife’s compliance. 

There was no direct admission by the husband that he was monitoring his wife to force her to abandon the divorce. 

However, the Appeals Court concluded that the trial judge could reasonably infer his intent from his repeated monitoring of her whereabouts, his unwanted appearances, and his continuing demands that she discontinue the divorce proceedings. 

This is an important recognition of how coercive control operates in practice. 

Abusive individuals rarely announce that their objective is to control another person. Instead, their intentions may be demonstrated through persistent behavior designed to undermine independence and compel a particular outcome. 

In this case, the husband’s actions supported the inference that he was using information about his wife’s movements and activities to create opportunities to pressure her into remaining in the marriage. 

3. A Loss of Autonomy Can Constitute Abuse

Perhaps the most consequential portion of the decision is the Appeals Court’s discussion of autonomy. 

The Court interpreted autonomy as an individual’s ability to make significant decisions without being constrained by concerns that doing so will expose them to abuse. 

The wife had made the decision to divorce. Yet the husband’s continued surveillance, unwanted intrusions, and repeated efforts to force reconciliation undermined her ability to move forward with that decision freely. 

The Court concluded that the evidence supported a finding that his conduct had reduced her sense of independence and personal freedom. 

This interpretation is especially significant in divorce and custody matters, where one party may attempt to maintain control over the other long after the relationship has ended. 

No individual should have to surrender their independence, abandon a divorce, or change their daily activities simply to avoid another person’s harassment or intimidation. 

4. Physical Violence Is Not Required

Historically, individuals seeking restraining orders in Massachusetts often faced difficulty when their experiences involved psychological intimidation or controlling behavior rather than physical violence or threats of imminent serious physical harm. 

The 2024 amendment provides an additional legal basis for protection. 

In Kehlani, the wife’s claim was based exclusively on coercive control. She did not rely on the other statutory categories of abuse. 

The Appeals Court concluded that her reasonably reduced sense of physical safety or autonomy was sufficient to support the order. 

This does not mean that every unpleasant interaction, contentious divorce, or disagreement between former partners constitutes coercive control. The statute requires proof of a qualifying pattern of behavior, the requisite intent, and a reasonable impact on the protected person’s safety or autonomy. 

However, it does mean that victims do not necessarily have to wait until controlling behavior escalates into physical violence before seeking legal protection. 

The Importance of Upholding the Coercive Control Law

The addition of coercive control to Chapter 209A was a meaningful step forward for Massachusetts domestic violence protections. But legislation is only as effective as its application in the courtroom. 

The Appeals Court’s decision in Kehlani demonstrates that the new statutory language has practical significance. 

By affirming the restraining order, the Court reinforced the Legislature’s recognition that domestic abuse can involve a systematic effort to deprive another person of independence and control over their own life. 

This is particularly important in family law matters. 

Divorce is often the point at which controlling behavior intensifies. A spouse who previously exercised control over household finances, communications, relationships, or daily activities may react to separation by increasing surveillance, harassment, or intimidation. 

For individuals attempting to leave controlling relationships, the ability to obtain meaningful legal protection can be essential. 

The decision also provides important guidance for attorneys and judges evaluating allegations of coercive control. Rather than focusing exclusively on isolated incidents or explicit threats, courts must consider the totality of the circumstances, including the purpose of the conduct and its cumulative effect on the person seeking protection. 

At the same time, the decision preserves the requirement that allegations be supported by evidence and that both parties receive a meaningful opportunity to be heard. 

What This Means for Massachusetts Families

For individuals experiencing domestic abuse, this decision reinforces that controlling behavior should not be dismissed simply because it does not involve physical violence. 

Repeated monitoring, unwanted appearances, interference with personal decisions, and efforts to undermine independence may constitute abuse when the statutory requirements are satisfied. 

For individuals navigating divorce or separation, it is also an important reminder that the end of a relationship does not eliminate a person’s right to privacy, autonomy, or personal safety. 

A spouse does not acquire the right to monitor, intimidate, or harass the other simply because they share children, own property together, or remain legally married. 

And a person’s refusal to accept the end of a relationship does not justify conduct designed to force reconciliation. 

Hera Law Group: Protecting Your Safety and Your Future

At Hera Law Group, we believe that everyone deserves to feel safe, respected, and empowered to make decisions about their own life. 

As family law attorneys, we understand that domestic abuse can take many forms and that coercive control can be particularly difficult to identify, document, and address during divorce and custody proceedings. 

The decision in Kehlani K. v. Tripp T. represents an important affirmation that Massachusetts law recognizes the harm caused by sustained patterns of controlling and intimidating behavior. 

You should not have to wait for physical violence to occur before exploring your legal options. 

If you are experiencing coercive control, harassment, intimidation, or other forms of domestic abuse, the attorneys at Hera Law Group can help you understand your rights, evaluate available legal protections, and navigate the intersection of abuse prevention orders, divorce, and custody proceedings. 

Contact Hera Law Group at 978-637-2048 or visit www.heralawgroup.com to schedule a consultation. 

Dedicated to what matters most. 

 

Legal Note: This article discusses the Massachusetts Appeals Court’s October 22, 2026, decision in Kehlani K. v. Tripp T., No. 25-P-960, and the coercive control provisions of M.G.L. c. 209A, § 1, as amended by St. 2024, c. 118. This article is intended for general informational purposes and does not constitute legal advice. Whether particular conduct qualifies as coercive control depends on the specific facts and circumstances of each case.