Mass. Gen. Laws » Part II Title III Chapter 210
Massachusetts General Laws

Mass. Gen. Laws ch. 210, § 6D (2026)

Enforcement of agreement

✓ current as of July 2026
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Section 6D. A party to a court-approved agreement for post-adoption contact or communication may seek to enforce the agreement by commencing a civil action for specific performance. A court order for specific performance of the terms of a post-adoption contact agreement shall be the sole remedy for breach of an agreement.

In such proceedings, parties shall not be entitled to the appointment of counsel; provided, however, that the court may appoint a guardian ad litem to represent the interests of the child.

In an enforcement proceeding, the court may modify the terms of the agreement if the court finds that there has been a material and substantial change in circumstances and the modification is necessary in the best interests of the child. A court-imposed modification of a previously approved agreement may limit, restrict, condition or decrease contact between the birth parents and the child but in no event shall a court-imposed modification serve to expand, enlarge or increase the amount of contact between the birth parents and the child or place new obligations on adoptive parents.

If the court finds that an action brought under this section was wholly insubstantial, frivolous and not advanced in good faith in accordance with the provisions of section 6F of chapter 231, the court may award attorney's fees to all prevailing parties.

Nothing in the agreement shall preclude a party seeking to enforce an agreement for post-adoption contact or communication from utilizing child welfare mediation or permanency mediation before, or in addition to, the commencement of a civil action for specific enforcement. All proceedings conducted under this section shall be closed to the public and confidential and papers shall be segregated in accordance with section 5D.

Notes of Decisions
Cited in 3 cases, 2000–2017 · leading case: Adoption of Vito, 728 N.E.2d 292 (Mass. 2000).
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Adoption of Vito, 728 N.E.2d 292 (Mass. 2000). · cites it 2× “With the possible, narrow exception of postadoption judicial modification of voluntary contact agreements between biological parents and adoptive parents, see G. L. c. 210, § 6D, we see nothing in the relevant, amended provisions of G.”
Adoption of Edgar, 853 N.E.2d 1068 (Mass. App. Ct. 2006). · cites it 2× “Finally, the children and the biological parents argue that the judge erred in revising the order for postadoption visitation because there was no showing of a “material and substantial change in circumstances,” as required by G. L. c. 210, § 6D, inserted by St. 1999, c.”
S.M. v. M.P. (Mass. App. Ct. 2017). · cites it 4× “See G. L. c. 210, § 6D; Adoption of Tammy, 416 Mass.”
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