Massachusetts General Laws

Mass. Gen. Laws ch. 221, § 51 (2026)

Failure to pay client's money; penalty

✓ current as of July 2026

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Section 51. An attorney at law who unreasonably neglects to pay over money collected by him for and in behalf of a client, when demanded by the client, shall forfeit to such client five times the lawful interest of the money from the time of the demand.

Notes of Decisions

Cited in 15 cases (1 in the last 5 years), 1956–2021 · leading case: Guenard v. Burke, 443 N.E.2d 892 (Mass. 1982).

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Guenard v. Burke, 443 N.E.2d 892 (Mass. 1982). · cites it 5× “The plaintiff asserted, under counts one and two, a claim for multiple interest on the withheld funds, relying on G. L. c. 221, § 51. The defendant counterclaimed for an additional $4,000 in legal fees.”

Doucette v. Kwiat (In Re Kwiat), 62 B.R. 818 (Bankr. D. Mass. 1986). · cites it 5× “Doucette brought suit against Kwiat, claiming that the defendant had violated G.L. c. 221 § 51 and G.L. c. 93A § 2 by allocating himself a fee for the lien settlements.”

Doucette v. Kwiat, 467 N.E.2d 1374 (Mass. 1984). · cites it 5× “2 Doucette has asserted that the defendant violated G. L. c. 221, § 51, 3 and G. L. c. 93A, § 2, in withholding the fee and paying certain expenses.”

In the Matter of Kerlinsky, 546 N.E.2d 150 (Mass. 1989). · cites it 2× “This conduct deserves public rebuke and an order for repayment accompanied by an assessment of penalty interest as provided for by G. L. c. 221, § 51 (1988 ed.). Order of the single justice affirmed.”

Frontier Enter., Inc. v. Anchor Co. of Marblehead, 536 N.E.2d 352 (Mass. 1989). · cites it 2× “Therefore, the only rights *511 Anchor-Marblehead had against Mr. Levin for any portion of the $45,000 were those general rights a client has to recover money an attorney receives on the client’s behalf.”

Kwiat v. Doucette, 81 B.R. 184 (D. Mass. 1987). “Mass.Gen.Laws ch. 221, § 51 provides: "An attorney at law who unreasonably neglects to pay over money collected by him for and in behalf of a client, when demanded by the client, shall forfeit to such client five times the lawful interest of the money from the time of the demand.”

Cameron v. Sullivan, 360 N.E.2d 890 (Mass. 1977). · cites it 2× “Sullivan, defendant, based on G. L. c. 221, § 51: “An attorney at law who unreasonably neglects to pay over money collected by him for and in behalf of a client, when demanded by the client, shall forfeit to such client five times the lawful interest of the money from the time…”

In the Matter of the Colecchia Fam. Irrevocable Trust., 100 Mass. App. Ct. 504 (Mass. App. Ct. 2021). “" [Note 18] Michael also argues that the trustees breached their duty of care by failing to pursue a claim against the trust's attorney under G. L. c. 221, § 51, which provides in full: "An attorney at law who unreasonably neglects to pay over money collected by him for and in…”

Hampshire Vill. Assocs. v. Dist. Court of Hampshire, 408 N.E.2d 830 (Mass. 1980). “130, § 24 (damage to shellfish or fishery resources); G. L. c. 221, § 51 (attorney’s failure to relinquish client’s money on demand); *151 G.”

Gannett v. Shulman, 908 N.E.2d 850 (Mass. App. Ct. 2009). “221, § 51 (“[A]n attorney at law who unreasonably neglects to pay over money collected by him for and in behalf of a client, when demanded by the client, shall forfeit to such client five times the lawful interest of the money from the time of the demand”).”

DeLano v. Milstein, 780 N.E.2d 107 (Mass. App. Ct. 2002). · cites it 2× “One of the grounds of the complaint alleged that Mil-stein’s refusal to pay over the funds was a violation of G. L. c. 221, § 51. Milstein failed to respond, and a default judgment entered.”

Grace & Nino, Inc. v. Orlando, 668 N.E.2d 864 (Mass. App. Ct. 1996). “93A and G. L. c. 221, § 51. The defendants’ counterclaim must be dismissed.”

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