Key Takeaways
Physical violence is not required. Massachusetts law now recognizes coercive control as a form of abuse under Chapter 209A, even when there has been no physical assault or explicit threat of violence.
A pattern of controlling behavior can qualify as abuse. Repeated monitoring, unwanted appearances, intrusions into a home, or other controlling conduct may constitute coercive control when the statutory requirements are satisfied.
Intent matters. The conduct must be intended to threaten, intimidate, harass, isolate, control, coerce, or compel compliance. A court may infer that intent from the circumstances rather than requiring a direct admission.
Reduced autonomy can be enough. A plaintiff does not necessarily need to prove fear of physical harm. Kehlani K. confirms that qualifying conduct may also support an order based on a reasonably reduced sense of physical safety or autonomy.
The effect must be reasonable. A subjective feeling of lost independence is not automatically sufficient. Courts must consider whether the reduction in safety or autonomy was reasonable under the circumstances.
Context matters in divorce cases. Ordinary disagreement, anger, or resistance to divorce is not automatically coercive control. Courts consider the entire course of conduct and the circumstances surrounding it.
The law is still developing. Kehlani K. v. Tripp T. is the first published Massachusetts Appeals Court decision interpreting the 2024 coercive-control provisions, and some questions remain unresolved.
What Kehlani K. v. Tripp T. Means for Coercive Control in Massachusetts
A new Massachusetts Appeals Court decision provides important guidance on when controlling conduct during a divorce can qualify as abuse even without physical violence or an explicit threat of violence.
In Kehlani K. v. Tripp T., No. 25-P-960, decided October 22, 2026, the Appeals Court upheld a one-year abuse prevention order against a husband whose repeated monitoring and unwanted appearances were found to constitute coercive control under Massachusetts law.
The decision is particularly significant because Massachusetts added coercive control to the definition of abuse under G.L. c. 209A in 2024. Kehlani K. is the first published Appeals Court decision to interpret and apply that new statutory language.
The court’s decision makes an important point clear: abuse under Chapter 209A is no longer limited to physical violence, sexual abuse, or conduct creating fear of imminent serious physical harm. A qualifying pattern of coercive or controlling behavior that reasonably reduces another person’s sense of physical safety or autonomy can also constitute abuse.
At the same time, the decision does not mean that every difficult interaction during a divorce is coercive control. The statute contains specific requirements, and the Appeals Court’s analysis shows why the context, purpose, pattern, and effect of the conduct all matter.
The Facts of Kehlani K. v. Tripp T.
The case arose during a contentious Massachusetts divorce involving a couple who had been married for seventeen years.
The wife had initiated divorce proceedings and testified that she was emotionally finished with the marriage, while the husband continued trying to persuade her to remain married. According to evidence credited by the District Court judge, he told the parties’ children that their mother did not want a family, told his wife that he was “never, ever leaving,” and continued asking her to call off the divorce.
Several months before the restraining order proceeding, a Probate and Family Court judge had given the wife sole and exclusive use and occupancy of the marital home.
The husband’s conduct nevertheless continued.
The wife testified that he appeared in her driveway almost daily, sometimes blocking her vehicle. Her doorbell camera recorded him walking around the home. He repeatedly entered the house when she was absent, even after she changed the locks, and on one occasion admitted entering through an unlocked window.
On another occasion, he entered the home without permission and photographed a calendar containing information about where the wife would be at different times.
His appearances were not limited to the marital home.
The wife testified that he appeared at a soccer game, at one of the children’s schools, outside a movie theater during a trip to New York, in the backyard of a vacation rental, and inside a hotel where she was staying. According to her testimony, these unexpected appearances continued for months.
The cumulative effect left her concerned that he was tracking her movements and caused her to remain constantly vigilant about where he might appear next.
What Did the District Court Decide?
The wife sought an abuse prevention order under G.L. c. 209A in October 2024.
A District Court judge initially issued an ex parte order directing the husband not to abuse or contact the wife and requiring him to stay away from her and her home.
At the later hearing after notice, the wife represented herself and the husband was represented by counsel. Both parties testified.
The judge found that the wife had met her burden of proving abuse and extended the order for one year.
Importantly, the wife’s claim was based specifically on the newly enacted definition of coercive control. She was not claiming that the husband had physically assaulted her, placed her in fear of imminent serious physical harm under the traditional Chapter 209A standard, or forced her to engage in sexual relations.
The husband appealed.
What Did the Massachusetts Appeals Court Decide?
The Appeals Court affirmed the one-year abuse prevention order.
The court concluded that the evidence was sufficient to establish coercive control under the newly amended definition of abuse in G.L. c. 209A, § 1.
The court identified three central components of the wife’s claim:
- a pattern of behavior by the husband;
- conduct intended to coerce or compel the wife’s compliance; and
- a reasonable reduction in the wife’s sense of physical safety or autonomy.
The Appeals Court concluded that the evidence supported all three.
The court also rejected the husband’s argument that he had been denied a meaningful opportunity to be heard at the restraining order hearing.
What Is Coercive Control Under Massachusetts Law?
Massachusetts expanded the definition of abuse under Chapter 209A in 2024 to include coercive control.
Under G.L. c. 209A, § 1, coercive control can be established through a pattern of behavior intended to threaten, intimidate, harass, isolate, control, coerce, or compel compliance of a family or household member when that conduct causes the other person to reasonably fear physical harm or experience a reduced sense of physical safety or autonomy.
The statute provides several examples of conduct that may be part of such a pattern, including:
- isolating a person from friends, relatives, or other support;
- depriving someone of basic needs;
- controlling or monitoring activities, communications, movements, finances, economic resources, or access to services;
- compelling someone to engage in or avoid particular conduct;
- threatening harm to children or relatives;
- threatening cruelty or abuse toward an animal;
- intentionally damaging property;
- threatening to publish sensitive personal information; and
- repeatedly pursuing court actions that a court finds are unsupported by existing law or a good-faith legal argument.
The statute also identifies several particularly serious single acts that can independently constitute coercive control.
Kehlani K. involved the pattern-of-behavior portion of the statute.
Physical Violence or Threats of Violence Are Not Always Required
One of the most significant aspects of Kehlani K. is what the plaintiff did not have to prove.
The Appeals Court did not rely on evidence that the husband physically assaulted the wife or explicitly threatened to hurt her.
Instead, the court focused on his repeated conduct, including monitoring her movements, entering and appearing around her home, learning her schedule, appearing unexpectedly at locations where she was present, and repeatedly attempting to persuade her to abandon the divorce.
The court specifically explained that its analysis did not depend on threatening communications.
That distinction is important because the coercive-control statute provides alternative ways in which qualifying conduct can affect the person experiencing it. A plaintiff may establish that the behavior caused a reasonable fear of physical harm, but the statute also applies when the behavior reasonably reduces the person’s sense of physical safety or autonomy.
In Kehlani K., the court concluded that the evidence was sufficient under the latter standard.
The Court Found a Pattern of Behavior
The first issue was whether the husband’s actions constituted a “pattern.”
Chapter 209A does not define that word.
The Appeals Court therefore applied its ordinary meaning, describing a pattern as a recognizable and consistent course or series of acts.
The court concluded that the husband’s repeated intrusions into the wife’s home and activities readily supported such a finding.
This is important because the court did not examine each incident in isolation. An unexpected appearance at a child’s activity, for example, could have an innocent explanation depending on the circumstances. The legal significance changed when the judge considered the repeated appearances together with unauthorized entries into the home, monitoring of the wife’s schedule, and other conduct occurring over a period of months.
Coercive-control cases can therefore require a court to examine the entire course of conduct rather than asking whether one isolated event independently amounted to abuse.
The Husband’s Intent Could Be Inferred From His Conduct
The statute also requires more than conduct that another person happens to dislike or find intrusive.
For the pattern at issue in Kehlani K., the conduct had to be intended to threaten, intimidate, harass, isolate, control, coerce, or compel compliance.
There was no direct admission from the husband that he was monitoring his wife for the purpose of forcing her to remain married.
The Appeals Court concluded that direct evidence of intent was unnecessary.
A judge could infer intent from the circumstances.
Here, the court connected the husband’s efforts to obtain information about the wife’s whereabouts and repeatedly appear in her life with his demands that she drop the Probate and Family Court proceeding, call off the divorce, and work on the marriage.
The combination permitted the trial judge to infer that the monitoring was intended to coerce or compel her to abandon the divorce.
This distinction matters. Persistent disagreement with a spouse’s decision to divorce is not itself coercive control. The question is whether the person’s conduct satisfies the requirements established by the statute.
What Does a “Reduced Sense of Autonomy” Mean?
Perhaps the most important legal interpretation in Kehlani K. concerns the meaning of autonomy.
The Appeals Court interpreted autonomy in this context to involve a person’s ability to make significant decisions without being constrained by concerns that doing so will expose the person to abuse.
The wife testified that the husband’s repeated monitoring left her looking over her shoulder and interfered with her sense of personal freedom and independence, including while she was in her own home.
The court concluded that this evidence supported a finding that her sense of autonomy had been reduced.
This portion of the decision significantly illustrates the reach of the 2024 law.
A person seeking an order based on coercive control does not necessarily have to establish that they believed a physical attack was imminent. A qualifying pattern of controlling conduct can satisfy the statute when it causes the person to reasonably experience a reduced sense of physical safety or autonomy.
The Reduction in Safety or Autonomy Must Be Reasonable
The Appeals Court also imposed an important limitation on the coercive-control standard.
It held that the word “reasonably” applies not only to fear of physical harm but also to a reduced sense of physical safety or autonomy.
In other words, it is not enough for a plaintiff simply to say that particular conduct made them feel less autonomous.
The reduction in safety or autonomy must be reasonable under the circumstances.
In Kehlani K., the court considered the entire relationship and course of conduct. Among other things, the trial judge credited evidence that the husband had entered the home despite the Probate and Family Court’s order granting the wife exclusive use and occupancy and later failed to immediately separate himself from her after an abuse prevention order containing stay-away and no-contact provisions had been issued.
Those circumstances were relevant to whether the wife’s response to his conduct was objectively reasonable.
Why the Divorce Context Mattered
Although Kehlani K. is a Chapter 209A case, its facts arose directly out of an ongoing divorce.
The husband’s alleged objective was not simply to monitor his wife’s movements. According to evidence credited by the trial judge, he repeatedly attempted to persuade or pressure her to terminate the divorce proceeding.
That connection is important.
Divorce often requires people who once shared a home, finances, children, schedules, and personal information to establish new boundaries. Former spouses may still need to interact because of parenting responsibilities, property issues, court proceedings, or other legitimate reasons.
Chapter 209A does not transform every unwanted interaction, argument, or disagreement during this process into abuse.
But the fact that conduct occurs during a divorce does not immunize it either. When one spouse engages in a statutory pattern of controlling behavior intended to compel the other’s compliance and that conduct produces the required effect on safety or autonomy, the coercive-control provisions may apply.
People dealing with these circumstances can learn more about Massachusetts protective orders through our Massachusetts restraining order resources.
What Kehlani K. Does Not Hold
Because coercive control is a relatively new basis for a Massachusetts abuse prevention order, it is particularly important not to read the decision more broadly than the court intended.
The decision does not hold that:
- every unwanted appearance by a spouse constitutes coercive control;
- repeatedly asking a spouse not to divorce is automatically abuse;
- difficult, angry, or unreasonable behavior during divorce necessarily satisfies Chapter 209A;
- a plaintiff must prove physical violence or an explicit threat of violence;
- every invasion of privacy constitutes coercive control;
- any subjective feeling that autonomy has been diminished is sufficient; or
- a specific minimum number of incidents is necessarily required to prove a pattern.
That last point deserves particular attention.
The Appeals Court noted that other Massachusetts statutes expressly require a certain number of acts to establish a pattern. Chapter 209A’s coercive-control provision does not.
The court therefore expressly left unresolved whether a future case might establish some minimum number of acts necessary to prove a pattern.
The Court Did Not Decide Every Constitutional Question About the New Law
The Appeals Court also made clear that Kehlani K. did not resolve every constitutional question surrounding the 2024 coercive-control statute.
The husband’s reliance on First Amendment precedent involving threatening speech did not affect the result because the court’s analysis rested on his conduct, not on threatening communications. The court expressly left the question of how the analysis might differ if an abuse prevention order were based solely on a defendant’s speech for a future case.
The court separately noted that the husband had not challenged the coercive-control statute as unconstitutional either on its face or as applied to him. It therefore did not decide whether the statute may be unconstitutionally vague or overbroad in other circumstances.
Those broader questions are now before the Massachusetts Supreme Judicial Court in G.P. v. S.P., a pending case involving numerous social-media videos critical of the plaintiff. The SJC has specifically requested briefing on both whether that speech can constitute coercive control and whether the coercive-control provision is unconstitutionally vague or overbroad.
For purposes of Kehlani K., however, the Appeals Court emphasized that its ruling rested on conduct such as monitoring the plaintiff’s movements and activities, repeatedly appearing at her home and other locations, entering her property, and using that conduct to pressure her to abandon the divorce.
How Could Kehlani K. Apply in Another Massachusetts Case?
Consider a separating couple who share children.
One parent repeatedly appears at children’s events. That fact alone may be entirely ordinary and appropriate.
Now change the circumstances.
Suppose a court has given one spouse exclusive possession of the marital home. The other spouse nevertheless repeatedly enters the property without permission, obtains information about the first spouse’s private schedule, begins appearing without explanation at locations unrelated to parenting responsibilities, and repeatedly states that the conduct will stop only if the divorce is abandoned.
Under Kehlani K., a court would not necessarily analyze each incident separately. It could consider whether the events collectively establish a pattern of monitoring or controlling behavior, whether the conduct was intended to compel compliance, and whether it reasonably diminished the other person’s physical safety or autonomy.
That does not mean the outcome would necessarily be the same. The credibility of the witnesses, the reasons for the conduct, the parties’ parenting responsibilities, existing court orders, and the totality of the circumstances would all matter.
What This Decision Means for Massachusetts Divorcing Spouses
For people going through divorce or separation, Kehlani K. demonstrates that Massachusetts courts may look beyond physical violence when evaluating allegations of domestic abuse.
Patterns of monitoring, unwanted intrusion, control, and interference with another person’s ability to make independent decisions may have legal significance under Chapter 209A when the statutory requirements are satisfied.
The decision is equally important for someone accused of coercive control.
Because ordinary family interactions can sometimes occur alongside allegations of controlling behavior, context matters. A court must still determine what actually occurred, whether the conduct formed the required pattern, what the defendant intended, and whether the effect on the plaintiff’s safety or autonomy was reasonable.
The standard remains proof by a preponderance of the evidence.
Does Kehlani K. Change Massachusetts Restraining Order Law?
The Legislature, not the Appeals Court, made the fundamental change to Chapter 209A in 2024. The 2024 legislation expanded the statutory definition of abuse to include coercive control.
Now, Kehlani K. begins the appellate process of explaining how that new definition should operate in real cases. Kehlani K. clarifies Massachusetts restraining order law rather than changing the statute itself. It provides the first published appellate interpretation of the important coercive-control language Massachusetts added to Chapter 209A.
Future appellate decisions will likely provide additional guidance about the boundaries of the statute.
Frequently Asked Questions About Coercive Control After Kehlani K.
Can I Obtain a Massachusetts Restraining Order Without Being Physically Assaulted?
Potentially, yes. Massachusetts law recognizes several forms of abuse under Chapter 209A, including coercive control, and Kehlani K. confirms that physical violence is not required for a coercive-control claim. The particular conduct must still satisfy the statutory requirements.
Does Someone Have to Threaten Me With Violence for Coercive Control to Apply?
No. Kehlani K. did not depend on an explicit threat of physical violence. A qualifying pattern may instead support relief if it reasonably reduces the person’s sense of physical safety or autonomy.
Is One Controlling Act Enough for a Restraining Order?
It depends on the conduct. One branch of Massachusetts’s coercive-control definition generally requires a pattern of behavior, while the statute separately identifies certain particularly serious single acts that can qualify on their own. Kehlani K. involved the pattern-of-behavior provision.
How Many Incidents Are Required to Prove a Pattern?
The Appeals Court did not establish a specific minimum number in Kehlani K. Chapter 209A does not currently state a numerical requirement for the pattern-of-behavior provision, and the court expressly left that question unresolved.
Is Refusing to Accept a Divorce Coercive Control?
Not by itself. A spouse may be angry, upset, or opposed to ending the marriage without necessarily committing abuse. The legal issue is whether the spouse engages in conduct satisfying the statutory requirements for coercive control.
Can Tracking or Monitoring a Spouse Qualify as Coercive Control?
Potentially. Massachusetts law specifically identifies controlling, regulating, or monitoring another person’s activities, communications, movements, finances, economic resources, or access to services as conduct that may form part of coercive control. Whether it meets the legal standard depends on the pattern, intent, effect, and surrounding circumstances.
Final Thoughts
Kehlani K. v. Tripp T. is an important early decision interpreting Massachusetts’s new coercive-control law.
Its significance lies partly in what was absent from the case. The Appeals Court did not require proof of a physical assault or an explicit threat of violence. Instead, it examined a months-long course of conduct involving monitoring, unauthorized intrusions, repeated appearances, pressure surrounding an ongoing divorce, and the resulting effect on the plaintiff’s safety and autonomy.
At the same time, the decision does not erase the statutory boundaries of Chapter 209A.
Coercive control requires more than proving that another person was difficult, intrusive, angry, or unwilling to accept the end of a relationship. Courts must examine the nature and pattern of the conduct, the purpose behind it, its effect on the plaintiff, and whether that effect was reasonable under the circumstances.
For Massachusetts families, the decision provides the clearest appellate guidance yet about how coercive control can operate during separation and divorce.
If you are seeking a Massachusetts abuse prevention order, responding to one, or dealing with allegations of coercive control during a divorce or custody matter, Turco Legal’s Massachusetts family law attorneys can help you understand how Chapter 209A and the developing appellate law may apply to your circumstances.
About the Author: Damian Turco is the Founder and Managing Partner of Turco Legal and has practiced divorce and family law since 2008.
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