Massachusetts Court Upholds Chapter 93A Liability for Landlord’s Excessive Rent Demand
The Massachusetts Appeals Court affirmed that landlord Hayastan Industries violated Chapter 93A by demanding more rent than the Guz tenants owed and then pursuing eviction on that basis. The tenants had lived in a mobile-home park for over two decades, and after Hayastan acquired their manufactured home, it accepted below-market monthly payments without reserving the right to end their occupancy, creating a tenancy at will. The court found the higher rent demand unfair and deceptive and a willful violation of the tenant quiet-enjoyment statute, supporting attorneys’ fees under Chapter 93A.
The Guzes had lived in a mobile-home park for more than twenty years. Hayastan Industries later acquired their manufactured home and accepted monthly payments below market without saying it retained a right to end their occupancy. The trial judge found a tenancy at will at that lower rent.
The Appeals Court agreed that demanding a larger amount and basing an eviction on it was unfair and deceptive under Chapter 93A. It also found a willful violation of the quiet-enjoyment law. The fee award was vacated because the lower court overemphasized the small damages relative to requested fees; appellate fees were allowed.
This ruling may encourage tenants to challenge rent demands that exceed agreed terms, especially in manufactured-home communities where long-term occupants can lack clear leases. It could also prompt landlords to document reservations of rights and avoid eviction threats tied to disputed amounts. Because appellate fees remain available even when damages are modest, the decision may affect how both sides weigh litigation risk and settlement. It does not itself change statutes, but may guide future Chapter 93A and quiet-enjoyment claims.