Ducharme v. Mobile Home Rent Control Board of Chicopee

CourtMassachusetts Appeals Court
DecidedMay 22, 2026
DocketAC 24-P-1132
StatusPublished

This text of Ducharme v. Mobile Home Rent Control Board of Chicopee (Ducharme v. Mobile Home Rent Control Board of Chicopee) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ducharme v. Mobile Home Rent Control Board of Chicopee, (Mass. Ct. App. 2026).

Opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557- 1030; SJCReporter@sjc.state.ma.us

24-P-1132 Appeals Court

LINDA DUCHARME vs. MOBILE HOME RENT CONTROL BOARD OF CHICOPEE & another.1

No. 24-P-1132.

Hampden. October 8, 2025. – May 22, 2026.

Present: Meade, Neyman, Walsh, JJ.

Mobile Home. Manufactured Housing Community. Municipal Corporations, Special act, Rent control. Administrative Law, Hearing, Judicial review, Standing, Substantial evidence. Housing Court, Jurisdiction. Jurisdiction, Housing Court. Rent Control, Mobile home, Rent increase, Judicial review. Practice, Civil, Review of action of rent control board, Review of administrative action, Standing.

Civil action commenced in the Western Division of the Housing Court Department on March 3, 2023.

The case was heard by Jonathan J. Kane, J., on motions for judgment on the pleadings.

Ryan K. O'Hara for the intervener. Daniel Ordorica for the plaintiff. Mark J. Albano, for the defendant, was present but did not argue.

1 Jean Real Estate, Inc., intervener. 2

NEYMAN, J. The plaintiff, Linda Ducharme, brought an

action in the Housing Court for review of a decision by the

mobile home rent control board of Chicopee (board) allowing the

defendant intervener, Jean Real Estate, Inc. (Jean), to increase

rent in three manufactured housing communities (parks). On

cross motions for judgment on the pleadings, a Housing Court

judge determined that due to technological issues with an

Internet-based video conferencing platform used during the

public hearing and inaudible portions of the resulting audio

recording and transcript, the board's decision must be set aside

because it was "in violation of constitutional provisions and

made upon unlawful procedure."

On appeal, Jean argues that the Housing Court lacked

jurisdiction over the matter, the plaintiff had standing only to

challenge the board's decision as to the one park where she is a

tenant, the plaintiff's substantial rights were not violated at

the hearing, the plaintiff waived her objections to the

technological issues at the hearing, and that the board's

decision was supported by substantial evidence. For the reasons

discussed herein, we vacate the judgment and remand for further

findings by the board only as to the park where the plaintiff

resides.

Background. 1. Regulatory scheme. In 1977, the

Legislature, through a special act, declared "a serious public 3

emergency" with respect to housing in the city of Chicopee

(city) "created by excessive, abnormally high and unwarranted

rental increases imposed by some owners of mobile parks located

therein." St. 1977, c. 596, § 1. To address the emergency, the

Legislature authorized the city to establish the board to

regulate rents in manufactured housing communities. See

St. 1977, c. 596, § 2.

The board is permitted to make individual or general

adjustments to rents to ensure that park owners receive a "fair

net operating income" for the units. St. 1977, c. 596, § 3 (a).

The special act and the related city ordinance define fair net

operating income as

"that income which will yield a return, after all reasonable operating expenses, on the fair market value of the property equal to the debt service rate generally available from institutional first mortgage lenders or such other rates of return as the board, on the basis of evidence presented before it, deems more appropriate to the circumstances of the case."

St. 1977, c. 596, § 3 (a). See City of Chicopee Ordinance

§ 195-5(B) (Ordinance § 195). The special act and the ordinance

also state that the fair market value of the property "shall be

the assessed valuation of the property or such other valuation

as the board, on the basis of evidence presented before it,

deems more appropriate to the circumstances of the case."

St. 1977, c. 596, § 3 (a); Ordinance § 195-5(C). Proceedings

before the board and judicial review of the board's final 4

decision are governed by G. L. c. 30A. See St. 1977, c. 596,

§§ 4, 5 (a); Ordinance § 195-7(A).

2. Facts. Jean is a corporation owned by Edison Yee, his

wife, and his siblings. Jean operates three parks in Chicopee -

- Holiday Mobile Home Park Phase I (Holiday I), Holiday Mobile

Home Park Phase II (Holiday II), and Kontiki Village Mobile Home

Park (Kontiki). These parks are situated on land owned by two

trusts. Edison Yee is the sole trustee of those trusts and his

mother, Linda Yee, is the beneficiary. The plaintiff is a

tenant of Holiday I.

In November 2022, Jean submitted three separate written

requests, along with supporting documentation, to the board

seeking rent increases at each of the parks (proposals). As to

Holiday I, Jean proposed a monthly rent increase of $150.08 for

each of the thirty-four sites, including the site occupied by

the plaintiff. At the time, Jean collected $89,279 annually in

rent at Holiday I. The monthly rent had not been adjusted since

2011 and ranged from $206.27 to $231.27 per site, depending on

lot size and location. In calculating the proposed rent

increase, Jean determined that Holiday I had reasonable

operating expenses of $59,513 and an appraised fair market value

of $1.3 million, and that a seven percent debt service rate was

applicable. Based on these amounts, Jean claimed a fair net 5

operating income of $150,513 annually (representing a $61,234

increase from the amount Jean was then collecting).

The plaintiff submitted written objections to Jean's

proposed rent increases to the board. On January 25, 2023, the

board held a public hearing on the three proposals. The hearing

was held in a "hybrid" format, with participants appearing in

person or using the Internet-based video conferencing platform,

Zoom Video Communications, Inc. (Zoom). Two members of the

board attended the hearing in person, and one appeared via Zoom.2

The hearing transcript reflects that at various times during the

hearing there were difficulties with the volume on Zoom such

that some remote participants (not including the board member)

complained about the audio during the proceeding.

The plaintiff's counsel, who appeared in person at the

hearing, made a presentation to the board.3 The plaintiff raised

two objections as to Holiday I. First, the plaintiff argued

2 The remaining two board members were excused from the hearing and did not vote. The chair of the board noted at the hearing that there was a quorum, and no party contends otherwise on appeal.

3 Although not dispositive on the issues before us, it appears that the plaintiff attended the hearing with counsel, and she does not argue that her ability to participate was hindered in any way. Rather, as discussed below, she argues that the extent of the technological issues was not apparent to the in-person participants during the hearing and thus could be raised for the first time before the Housing Court judge. 6

that the board should determine the fair market value for the

property based on its "assessed" value of $700,100, as "is

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