Coercive Control at a Chapter 209A Extension Hearing: Kehlani K. v. Tripp T.

By Attorney Joe Serpa | Georgetown University Law Center

October 26, 2026

On October 22, 2026, the Massachusetts Appeals Court decided Kehlani K. v. Tripp T., No. 25-P-960, a published decision applying the coercive control definition that the Legislature added to the abuse prevention statute, G. L. c. 209A, in 2024. The plaintiff obtained an abuse prevention order against her husband and later asked a Probate and Family Court judge to extend it. The judge extended the order for one year.

The husband appealed, and the Appeals Court upheld the extension, holding that the plaintiff’s testimony proved abuse by coercive control. This article explains the coercive control definition, the evidence the court found adequate to meet it, and what the decision means for a person on either side of a 209A extension hearing.

What the 2024 Amendment Added to Chapter 209A

The 2024 amendment made coercive control a fourth form of abuse under G. L. c. 209A, § 1. Before the amendment, a plaintiff proved abuse by showing that the defendant caused or attempted physical harm, placed the plaintiff in fear of imminent serious physical harm, or caused the plaintiff to engage involuntarily in sexual relations by force, threat, or duress. A plaintiff can now also prove abuse by showing coercive control.

The statute defines coercive control as a pattern of behavior intended to threaten, intimidate, harass, isolate, control, coerce, or compel the compliance of a family or household member that causes that person reasonably to fear physical harm or to have a reduced sense of physical safety or autonomy. The statute then lists examples, including isolating the person from friends and relatives, depriving the person of basic needs, monitoring the person’s activities, communications, movements, or finances through technological or other means, and damaging the person’s property. The list gives examples and does not limit the conduct that can qualify.

The Evidence the Appeals Court Found Adequate

The Appeals Court held that the plaintiff’s credited testimony proved each part of the coercive control definition. The court broke the definition into three questions and answered each one on the hearing record.

First, the court found a pattern of behavior. Because the statute does not define “pattern,” the court applied the ordinary meaning of the word, a mode of behavior or series of acts that are recognizably consistent. The plaintiff testified that the husband repeatedly intruded into her home and her activities, and the court held that this testimony established a pattern.

Second, the court found that the husband intended the pattern to coerce or compel the plaintiff’s compliance. The plaintiff testified that the husband maintained a presence in and around her home at all hours of the day and, on at least one occasion, photographed her daily calendar. The court held that this conduct was monitoring of the plaintiff’s activities and movements. The court further held that the husband used the information he gathered to press the plaintiff to drop the divorce, and that a judge may infer intent from conduct even without direct evidence of intent.

Third, the court found that the pattern caused the plaintiff a reduced sense of physical safety or autonomy. The plaintiff testified that the husband entered her house through a window, circled her home on foot, blocked her car in the driveway, and appeared to track her movements, and that she feared him for those reasons. The court held that this evidence satisfied the reduced sense of physical safety. The court added that the same evidence satisfied the reduced sense of autonomy, which the court defined as a person’s ability to make significant decisions without concern that making them will expose the person to abuse.

The Defendant’s Due Process and Confrontation Claims

The husband argued that the judge denied him a meaningful opportunity to be heard because the plaintiff referred to photographs during her closing argument without offering them in evidence during her testimony. The Appeals Court rejected that argument. A judge has broad discretion over the scope of cross-examination, and in a 209A proceeding the rules of evidence need not be followed as long as the judge is fair in what evidence the judge admits and relies on. See Frizado v. Frizado, 420 Mass. 592 (1995). The court noted that the photographs illustrated subjects on which the husband had already cross-examined the plaintiff at length.

The husband separately argued that the judge wrongly limited the follow-up questions his counsel could ask him. The Appeals Court declined to address that argument because the husband’s brief cited no part of the record and amounted to a bald assertion of error. A party who raises an argument on appeal must cite the parts of the record the party relies on, and a party who does not do so forfeits the argument.

What the Decision Means for a 209A Extension Hearing

A plaintiff can prove abuse under G. L. c. 209A through coercive control without proving a fear of imminent serious physical harm. Conduct that is not physical, such as repeated surveillance, following, and monitoring, can meet the coercive control definition when it forms a consistent pattern and the defendant intends it to control or compel the plaintiff. A judge may infer the defendant’s intent from the conduct itself.

A respondent who contests an extension should test each part of the definition on the record. The respondent can contest whether the conduct forms a consistent pattern, whether the defendant intended it to coerce or compel the plaintiff, and whether it caused the plaintiff a reasonable and reduced sense of physical safety or autonomy.

A respondent who wants to preserve an evidentiary ruling for appeal must object on the record at the hearing and, in any later brief, cite the part of the record where the ruling occurred. Attorney Joe Serpa has practiced Massachusetts criminal defense since 1995 and represents both plaintiffs and respondents at abuse prevention hearings in the District Court and the Probate and Family Court.

Key Takeaways

• In Kehlani K. v. Tripp T., No. 25-P-960 (Oct. 22, 2026), the Massachusetts Appeals Court upheld the one-year extension of an abuse prevention order on a finding of coercive control.
• The 2024 amendment to G. L. c. 209A, § 1 makes coercive control a form of abuse, defined as an intended pattern of controlling behavior that causes a reasonable fear of physical harm or a reduced sense of physical safety or autonomy.
• The court held that the husband’s repeated presence around the plaintiff’s home, his monitoring of her movements, and his photographing of her calendar formed a pattern he intended to use to compel her to drop the divorce.
• The court defined autonomy as a person’s ability to make significant decisions without concern that making them will expose the person to abuse.
• A plaintiff can prove abuse through coercive control without proving a fear of imminent serious physical harm, and a judge may infer the defendant’s intent from the defendant’s conduct.
• A respondent who wants to challenge an evidentiary ruling on appeal must object at the hearing and cite the record in any later brief.

Related Serpa Law Office resources

• What Is Coercive Control Under Massachusetts 209A Law?
• Massachusetts 209A Extension Hearings: Evidence and Burden
• Massachusetts Restraining Order and Harassment Prevention Order Appeals: The Week of October 19, 2026
• Massachusetts 209A Restraining Orders (Abuse Prevention Orders): Defense and Plaintiff Representation
• Massachusetts Restraining Orders and Harassment Prevention Orders
• The Fifth Amendment at the 209A Restraining Order Hearing and in Civil Cases