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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Brown v. LeClair, 20 Mass. App. Ct. 976 (1985)

Citation
Brown v. LeClair, 20 Mass. App. Ct. 976 (1985)
Parent Document
Brown v. LeClair, 20 Mass. App. Ct. 976 (1985)
Jurisdiction
Massachusetts (state)
Effective Date
1985-09-11

Full Text

975 chars
The judge’s award based on a wilful or knowing violation is supported by evidence that the previous tenant, who moved out in 1979, was unsuccessful in obtaining repairs and that some of the problems (leaks) had persisted for three and a half years and continued to the time of the trial in 1983. While each violation may not in itself have been wilful, e.g., the inadequate door, we think that where, as here, there were many continuing violations, some major and some minor, their cumulative effect on habitability can be considered by the trial judge in determining whether Brown’s behavior was wilful. Cf. McKenna v. Begin, 5 Mass. App. Ct. at 308. Even if each violation must, for purposes of c. 93A, be considered separately, we think the judge’s additional finding of bad faith in responding to LeClair’s demand letter — the alternate prong permitting an assessment of punitive damages — leaves no doubt of the judge’s finding sufficient ground to award treble damages.