Massachusetts General Laws

Mass. Gen. Laws ch. 21E, § 15 (2026)

Citizen enforcement

✓ current as of July 2026

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Section 15. In any suit by Massachusetts residents to enforce the requirements of this chapter, or to abate a hazard related to oil or hazardous materials in the environment, the court may award costs, including reasonable attorney and expert witness fees, to any party other than the commonwealth who advances the purposes of this chapter.

Notes of Decisions

Cited in 16 cases (1 in the last 5 years), 1992–2022 · leading case: Bank v. Thermo Elemental Inc., 451 Mass. 638 (Mass. 2008).

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Bank v. Thermo Elemental Inc., 451 Mass. 638 (Mass. 2008). · cites it 5× “12, § 111 (civil rights act); G. L. c. 21E, § 15 (citizen enforcement of environmental protection statute) 33 ; G.”

Thomas & Betts Corp. v. Alfa Laval, Inc., 915 F.3d 36 (1st Cir. 2019). · cites it 3× “" Mass. Gen. Laws ch. 21E, § 15. 17 New Albertson's requested attorney's fees pursuant to this section.”

Sanitoy, Inc. v. Ilco Unican Corp., 602 N.E.2d 193 (Mass. 1992). · cites it 4× “After trial, both parties moved to recover attorneys’ fees and expert witness fees pursuant to G. L. c. 21E, § 15. The judge ruled that “eligibility for costs and attorneys’ fees depends upon a party’s entitlement to response costs.”

Thomas & Betts Corp. v. New Albertson's, Inc., 210 F. Supp. 3d 282 (D. Mass. 2016). · cites it 5× “Mass. Gen. Laws ch. 21E, § 15. As the language of Section 15 makes clear, recovery is available only to Massachusetts residents.”

Black v. Coastal Oil New England, Inc., 785 N.E.2d 708 (Mass. App. Ct. 2003). · cites it 7× “48 in attorney’s fees and costs under G. L. c. 21E, § 15. Id. at 462. After an appeal by the defendant, we affirmed the portion of the judgment for response costs under § 4; reversed the portion of the judgment for damage to the realty under § 5 3 ; vacated the award of…”

Martignetti v. Haigh-Farr, Inc., 425 Mass. 294 (Mass. 1997). · cites it 2× “plaintiff (current landowner) had neither contributed to nor caused the contamination, but the judge had refused to award attorneys’ fees under G. L. c. 21E, § 15. Citing Sanitoy, supra at 631 , we remanded for reconsideration.”

Black v. Coastal Oil New England, Inc., 699 N.E.2d 353 (Mass. App. Ct. 1998). · cites it 2× “48 in fees and costs under G. L. c. 21E, § 15. We affirm in part and reverse in part.”

Hill v. Metro. Dist. Comm'n, 439 Mass. 266 (Mass. 2003). “(b) We also conclude that the judge did not abuse her discretion in denying A & P’s motion for expert and attorney’s fees under G. L. c. 21E, § 15, set forth below, 15 from both defendants.”

Buddy's Inc. v. Town of Saugus, 816 N.E.2d 134 (Mass. App. Ct. 2004). “294, 322 (1997) (contrasting § 4A with G. L. c. 21E, § 15, which allows only “innocent” parties to recover attorney’s fees and costs).”

Grand Manor Condo. Ass'n & Others v. City of Lowell., 100 Mass. App. Ct. 765 (Mass. App. Ct. 2022). · cites it 3× “In the circumstances of complicated and lengthy litigation involving damages arising from environmental contamination, the judge's award of attorney's fees, expert fees, and costs under G. L. c. 21E, § 15, was not excessive. [773-774] Page 766 CIVIL ACTION commenced in the…”

All Brands Container Recovery, Inc. v. Merrimack Valley Distrib. Co., 764 N.E.2d 931 (Mass. App. Ct. 2002). “Contrast G. L. c. 21E, § 15 (“In any suit by Massachusetts residents to enforce .”

Thomas & Betts Corp. v. New Albertson's, Inc., 187 F. Supp. 3d 229 (D. Mass. 2016). “Award Att’ys’ Experts’ Fees Costs Pursuant M.G.L. c. 21E, § 15, ECF No. 866. The Court has allowed Thomas & Betts until May 2, 2016 to respond to these motions.”

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