Domestic abuse does not always involve physical violence. Sometimes it involves a spouse or partner who monitors your movements, controls your money, interferes with your relationships, or makes you afraid to make decisions without their approval.
Massachusetts law now recognizes this type of behavior as coercive control, and a new Appeals Court decision explains how the law protects people experiencing it.
What Is Coercive Control?
In September 2024, Massachusetts expanded its domestic abuse prevention law, G.L. c. 209A, to include coercive control as a form of abuse.
Coercive control generally involves a pattern of behavior intended to intimidate, isolate, threaten, or control another person, causing that person to reasonably fear physical harm or experience a reduced sense of physical safety or personal independence.
Examples may include:
- Monitoring someone’s telephone calls, messages, whereabouts, or daily activities.
- Following or tracking someone’s movements.
- Controlling access to money, bank accounts, or other financial resources.
- Preventing someone from seeing friends or family members.
- Threatening to harm children, relatives, or pets.
- Intentionally damaging someone’s property.
- Threatening to disclose sensitive personal information or intimate photographs.
Not every disagreement, unpleasant interaction, or controlling behavior constitutes coercive control under the law. The conduct must satisfy the statutory requirements.
The law also recognizes certain particularly serious single acts as coercive control, including specified acts involving harm to children or relatives, abuse of animals, or the publication of sexually explicit images.
A New Massachusetts Appeals Court Decision
On October 22, 2026, the Massachusetts Appeals Court decided Kehlani K. v. Tripp T., No. 25-P-960. This is the first published Massachusetts appellate decision interpreting the new coercive control law.
The parties had been married for seventeen years and were involved in divorce proceedings.
The wife obtained an abuse prevention order against her husband. Although the case did not depend on evidence that he physically assaulted her, she described repeated behavior that interfered with her ability to live independently.
According to the evidence credited by the trial judge, the husband entered her home without permission, appeared around her home at various hours, monitored her activities, and photographed her calendar. He also appeared at locations where she was spending time and repeatedly pressured her to abandon the divorce.
The wife testified that she felt she constantly had to look over her shoulder and felt threatened.
The District Court extended the abuse prevention order for one year. The husband appealed.
What Did the Appeals Court Decide?
The Appeals Court upheld the restraining order.
The court concluded that the husband’s repeated monitoring of his wife’s activities and movements constituted a pattern of behavior that the judge could reasonably find was intended to pressure her into abandoning the divorce.
Importantly, the court explained that coercive control does not necessarily require proof that the victim feared an imminent physical assault.
Instead, the law also protects someone whose sense of physical safety or autonomy has been reasonably reduced by another person’s controlling behavior.
The court described autonomy as the ability to make significant decisions without being constrained by concerns that doing so will expose the person to abuse.
The wife’s testimony that she constantly looked over her shoulder, together with the husband’s repeated intrusions into her home and personal activities, was sufficient to support the restraining order.
What Questions Did the Appeals Court Leave Unanswered?
Although Kehlani K. is the first published Massachusetts appellate decision interpreting coercive control, it does not answer every question about the new law.
For example, the law requires a pattern of behavior in most coercive control cases, but it does not expressly define how many incidents are necessary to establish that pattern.
The Appeals Court specifically declined to decide the minimum number of acts required. The Massachusetts Trial Court’s published guidelines describe a pattern as three or more acts, but the Appeals Court left the question of the statutory minimum for another case.
The decision is also very fact-specific. The husband repeatedly monitored his wife’s activities, entered her home without permission, disregarded court orders, and attempted to pressure her into abandoning the divorce.
These circumstances provided substantial evidence of coercive control.
However, not every person experiencing controlling behavior will have evidence involving repeated unauthorized entries into a home, violations of court orders, or pressure to abandon a divorce.
As the first published appellate decision interpreting the new law, Kehlani K. provides important guidance, but it may not provide adequate guidance to every person who believes they are being victimized by coercive control. Additional court decisions will be needed to clarify how the law applies to other situations.
What Does This Mean for Someone Going Through a Divorce?
Divorce can be an especially difficult time when one spouse refuses to accept that the marriage is ending.
A spouse may repeatedly telephone or text, monitor the other spouse’s activities, appear unexpectedly at locations, use the children to deliver unwanted messages, make false statements about the other parent to the children, or apply financial pressure to try to prevent the divorce.
Some of these actions, particularly when they form a pattern intended to control the other spouse, may constitute coercive control.
However, these behaviors do not automatically constitute coercive control. Their purpose, frequency, context, and effect on the other spouse matter. For example, making false statements about the other parent to children may be relevant to a custody dispute without necessarily satisfying the legal definition of coercive control.
The important question is not simply whether the controlling spouse has made an explicit threat of violence. It is whether the conduct meets the legal definition of coercive control and has reasonably affected the other person’s sense of safety or independence.
In Kehlani K., the husband’s efforts to pressure his wife to discontinue the divorce were particularly important. The court concluded that his monitoring of her activities could reasonably be understood as a way of compelling her to remain in the marriage.
Can You Obtain a Restraining Order Without Physical Violence?
Yes.
Under G.L. c. 209A, a person may qualify for an abuse prevention order based on coercive control even without being physically assaulted.
The person requesting protection must establish abuse by a preponderance of the evidence. This means showing that it is more likely than not that the conduct satisfies the law.
Evidence may include text messages, emails, financial records, photographs, witness testimony, or descriptions of repeated incidents.
A judge must consider the circumstances of the relationship and determine whether the statutory requirements have been satisfied.
Does Every Controlling Spouse Qualify as an Abuser?
No.
Married couples frequently disagree about money, children, living arrangements, and whether to remain married.
The law does not make every argument or attempt at persuasion a form of domestic abuse.
The distinction is whether the conduct constitutes coercive control as defined by the statute.
In Kehlani K., the Appeals Court emphasized the husband’s repeated intrusions, monitoring, and efforts to compel his wife to abandon the divorce. It also considered the effect of that conduct on her sense of safety and independence.
The decision does not mean that every unwanted communication between divorcing spouses justifies a restraining order.
Protecting Yourself from Coercive Control
If you believe your spouse or partner is using intimidation, surveillance, financial pressure, or other controlling behavior against you, consider documenting what is happening.
Keep copies of relevant messages and records, and make notes about incidents, including when they occurred and whether anyone witnessed them.
You should also consider speaking with an attorney about your rights and whether the circumstances justify requesting an abuse prevention order.
You do not have to wait until someone physically assaults you before seeking legal advice.
The Bottom Line
The Massachusetts Appeals Court’s decision in Kehlani K. v. Tripp T. recognizes that domestic abuse can involve more than physical violence.
A spouse who repeatedly monitors, intimidates, or interferes with another spouse’s independence may be engaging in coercive control, even without making an explicit threat of physical injury.
The decision is an important first step in interpreting the new law, but many questions remain unanswered. Future decisions will help establish where the law draws the line between difficult relationships and legally actionable coercive control.
The purpose of the law is to protect people not only from physical harm, but also from patterns of abuse that deprive them of the freedom to make important decisions about their own lives.
No one should have to surrender their independence or remain in an unwanted marriage because they are afraid of how their spouse will react.
