Howe v. Palmer
Court of Appeals of Massachusetts
956 N.E.2d 249 (2011)
Over several years, Ronald and Jeanette Palmer (defendants) cultivated a close, manipulative relationship with Virgil Howe (plaintiff), a simple, dyslexic, easily intimidated man worried about losing his family farm; Ronald offered help, moved onto the farm with Jeanette, disposed of junk and kept the proceeds, then convinced Howe he owed them $20,000–$25,000 for the cleanup and needed to sign over a 50% deed interest to settle the debt, which Jeanette's lawyer drafted. The Palmers then started a religious ministry that pressured Howe into further "counseling" and "loyalty," though Howe eventually reconciled with his wife and both eventually left the farm. Howe sued within a year, alleging the deed resulted from undue influence and also raising intentional-infliction-of-emotional-distress claims; a jury found for Howe, and the court rescinded the deed and awarded $60,000. The Palmers appealed.
Whether a person may void written obligations procured by undue influence.