Massachusetts General Laws

Mass. Gen. Laws ch. 185, § 114 (2026)

Changes upon registration book; grounds for motion to change

✓ current as of July 2026

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Section 114. (a) No erasure, alteration or amendment shall be made upon the registration book after the entry of a certificate of title or of a memorandum thereon and the attestation of the same by the recorder or an assistant recorder without court order, except in an instance in which the assistant recorder, upon approval of the chief title examiner of the land court or their designee, determines that a clerical error or omission has been made in the entry of the certificate of title or memorandum thereon.

(b) A registered owner or other person in interest may apply by complaint to the court upon the grounds that: (i) registered interests of any description, whether vested, contingent, expectant or inchoate, have terminated and ceased; (ii) new interests not appearing upon the certificate have arisen or been created; (iii) an error or omission was made in entering a certificate or any memorandum thereon; (iv) the name of any person on the certificate has been changed; (v) the registered owner has married, or if registered as married, that the marriage has been terminated; (vi) a corporation which owned registered land and has been dissolved has not conveyed the same within 3 years after its dissolution; or (vii) upon any other reasonable ground, and the court may hear and determine the complaint after notice to all parties in interest, and may order the entry of a new certificate, the entry or cancellation of a memorandum upon a certificate, or grant any other relief upon such terms, requiring security if necessary, as it may consider proper; provided, however, that this section shall not authorize the court to open the original judgment of registration; and provided further, that nothing shall be done by the assistant recorder or ordered by the court that shall impair the title or other interest of a purchaser holding a certificate for value and in good faith, or their heirs or assigns, without their written consent.

Notes of Decisions

Cited in 23 cases (4 in the last 5 years), 1927–2025 · leading case: Colony of Wellfleet, Inc. v. Harris, 883 N.E.2d 1235 (Mass. App. Ct. 2008).

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Colony of Wellfleet, Inc. v. Harris, 883 N.E.2d 1235 (Mass. App. Ct. 2008). · cites it 7× “The Colony argues that the Land Court judge (1) had a duty under G. L. c. 185, § 114, to expunge an errone *523 pus registration of a deed in fee where the transferee was not a purchaser in good faith; (2) committed an error of law in ruling that the Colony ratified the 1978…”

Doyle v. Commonwealth, 830 N.E.2d 1074 (Mass. 2005). · cites it 7× “Where a certificate of title to registered land is defective on its face and was issued in error, we conclude that a Land Court judge has the authority sua sponte to review the validity of such a certificate, a power that is both consistent with a court’s authority in a…”

Wild v. Constantini, 615 N.E.2d 557 (Mass. 1993). · cites it 4× “G.L.c. 185, § 114 (1990 ed.). A judge in the Land Court entered judgment in the plaintiffs' favor and the defendant appeals.”

Assistant Recorder of the North Registry Dist. v. Spinelli, 651 N.E.2d 411 (Mass. App. Ct. 1995). · cites it 4× “at 354, and that it need not resolve certain questions raised by the parties under G. L. c. 185, § 114. Id. at 355. Spinelli’s argument that the assistant recorder does not have the power to petition the court to amend a certificate of title that contains an error recognized by…”

Arno v. Commonwealth, 931 N.E.2d 1 (Mass. 2010). · cites it 2× “However, since this case arises from an action seeking to clarify the scope of the public’s rights in Amo’s parcel, G. L. c. 185, § 114, the public’s rights, whether by “easement” or “condition subsequent,” should be reflected in a new certificate of title.”

Sullivan v. Kondaur Capital Corp., 7 N.E.3d 1113 (Mass. App. Ct. 2014). “More broadly, G. L. c. 185, § 114, authorizes any “registered owner or other person in interest” to bring a motion to correct a certificate of title upon various grounds, including “that any error or omission was made in entering a certificate or any memorandum thereon,”…”

Commonwealth Elec. Co. v. MacCardell, 450 Mass. 48 (Mass. 2007). · cites it 2× “Consequently, it petitioned the Land Court pursuant to G. L. c. 185, § 114, to amend the defendant’s certificate of title for Lot 1 to hold the easement.”

Cities Serv. Oil Co. v. Gen. Dynamics Corp., 437 N.E.2d 247 (Mass. App. Ct. 1982). · cites it 5× “” See G. L. c. 185, § 114. 2 The defendant’s argument is two-pronged.”

Commonwealth Elec. Co. v. MacCardell, 849 N.E.2d 910 (Mass. App. Ct. 2006). · cites it 3× “NStar thereupon brought this action, pursuant to G. L. c. 185, § 114, seeking to have MacCardell’s certificate amended by noting on its encumbrance sheet that lot 1 is subject to an easement in NStar’s favor.”

Lassman v. HSBC Bank USA., N.A. (In re DeMore), 530 B.R. 519 (Bankr. D. Mass. 2015). · cites it 3× “He observes that the registration system also includes title curative procedures, including those set forth in Mass. Gen. Laws ch. 185, § 114 , which provides, inter alia, that a registered owner or other person in interest may apply by motion to the court to correct “any error…”

Feldman v. Souza, 538 N.E.2d 64 (Mass. App. Ct. 1989). “The occasion for those findings was a complaint brought by the Feldmans under G. L. c. 185, § 114, demanding that the easement in their favor be noted on the Souzas’ certificate of title.”

In Re Bailey, 468 B.R. 464 (Bankr. D. Mass. 2012). “[19] There is no indication, despite its broad language, that the Land Court Order applied to any property other than the property affected by the registered certificate of title at issue in that case. The Property here, in fact, is not registered land.”

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