Serreze v. YWCA of Western Massachusetts

Massachusetts Appeals Court · Property

Propertyself-help evictionquiet enjoymentoccupantresidential premisestransitional housingsummary processG. L. c. 186 § 14

Facts

The YWCA operated a Transitional Living Program for battered women and their children in apartments it leased in Northampton, combining subsidized housing with social services. Each plaintiff lived in her own apartment, paid monthly rent equal to twenty-five percent of her income, and had exclusive possession and control under the program agreements. After disputes over the program coordinator and the plaintiffs' participation in counseling sessions, the YWCA gave notices to vacate and warned that locks would be changed if they did not leave. During a DSS conciliation conference, YWCA representatives left the meeting and changed the locks on the plaintiffs' apartment doors.

Issue

Whether women residing in YWCA-operated chapter 707 project-based units in a transitional housing program were protected by G. L. c. 186, § 14 from being locked out without judicial process, even if their relationship with the YWCA was not a classic tenancy. Also, whether the YWCA's conduct constituted a civil rights violation under G. L. c. 12, § 111.

Rule

G. L. c. 186, § 14 does not require the existence of a classic landlord-tenant relationship; it protects any occupant of residential premises from interference with quiet enjoyment and from efforts to regain possession by force without judicial process. A claim under the Massachusetts Civil Rights Act requires threatened, intimidated, or coerced conduct directed toward a particular individual or class of persons.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

A nonprofit in Worcester operates a transitional housing program for survivors of domestic abuse. Under written agreements, residents live in separate apartments, pay monthly rent equal to 30% of their income, and receive counseling services; after a dispute about missed meetings, the nonprofit changes a resident's locks without going to court, arguing she was only a program participant and not a tenant.

Under the majority rule, which is the strongest argument for the resident's claim under G. L. c. 186, § 14?

Explanation. The majority focused on the statutory text protecting the quiet enjoyment of any residential premises by the occupant and barring efforts to regain possession by force without judicial process. A classic landlord-tenant relationship is not required. Because the resident occupied residential premises and was locked out through self-help, § 14 applies even if the provider characterizes her as a program client. (Derived from Serreze v. YWCA of Western Massachusetts (n.d.).)