Boston Housing Auth. v. Hemingway, 363 Mass. 184 (1973)

Holding:
Massachusetts Supreme Judicial Court adopted the implied warranty of habitability for residential leases. Held that a substantial breach of the warranty is grounds for the tenant to withhold rent and assert it as a defense to summary process under ch. 239 § 8A. Quantification: rent abatement equal to the difference between the rent reserved and the fair rental value of the premises in their defective condition. The decision integrates with G.L. ch. 111 § 127L (repair-and-deduct) and ch. 186 § 14 (quiet enjoyment) as the three pillars of MA tenant habitability rights.