Massachusetts General Laws

Mass. Gen. Laws ch. 266, § 31 (2026)

Signature; obtaining under false pretenses

✓ current as of July 2026

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Section 31. Whoever by a false pretence, with intent to defraud, obtains the signature of a person to a written instrument, the false making whereof would be a forgery, shall be punished by imprisonment in the state prison for not more than ten years, or by a fine of not more than five hundred dollars and imprisonment in the jail for not more than two years.

Notes of Decisions

Cited in 6 cases (1 in the last 5 years), 1964–2025 · leading case: Commonwealth v. Levin, 417 N.E.2d 440 (Mass. App. Ct. 1981).

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Commonwealth v. Levin, 417 N.E.2d 440 (Mass. App. Ct. 1981). · cites it 2× “267, § 5), fraudulently obtaining signatures by false pretenses (G. L. c. 266, § 31), larceny (G. L. c. 266, § 30), and attempted larceny (G.”

Commonwealth v. St. Hilaire, 21 N.E.3d 968 (Mass. 2015). “1 The judge found the defendant not guilty of obtaining a signature under false pretenses in violation of G. L. c. 266, § 31. 2 Due to the length of time that has elapsed since the trial in this case, the judge was unable to respond to an order of this court seeking…”

Commonwealth v. Kiernan, 201 N.E.2d 504 (Mass. 1964). “208, § 27 (now G. L. c. 266, § 31), defining the crime of false pretences by the fraudulent obtaining of “the signature of a person to a written instrument,’’ was also extant at the time of the Friedman decision.”

Commonwealth v. Hildreth, 572 N.E.2d 18 (Mass. App. Ct. 1991). “The defendant was also convicted on numerous counts of obtaining signatures on promissory notes by false pretenses, G. L. c. 266, § 31, and of obtaining, by false pretenses and with the intent to defraud, the making of promissory notes.”

Commonwealth v. Christopher, 104 N.E.3d 682 (Mass. App. Ct. 2018). · cites it 2× “Following a jury-waived trial in the Superior Court, the defendant, Kathryn Christopher, was convicted of obtaining, by false pretenses, the signature of an eighty-eight year old woman suffering from end-stage Alzheimer's disease, in violation of G. L. c. 266, § 31. The…”

Commonwealth v. John J. Donovan. (Mass. App. Ct. 2025). · cites it 2× “He argues that there was no evidence that the defendant made any representations to Clocher about the affidavit, false or otherwise, and the affidavit was not a written instrument within the meaning of G. L. c. 266, § 31. Based upon the evidence presented, jurors could…”

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