In MacDonald v. Caruso, SJC-11381, March 11, 2014, the Supreme Judicial Court ruled that when a defendant seeks to end a permanent abuse prevention order, they "must show by clear and convincing evidence that, as a result of a significant change in circumstances, it is no longer equitable for the order to continue because the protected party no longer has a reasonable fear of imminent serious physical harm."
They go on to "direct judges to place their findings of fact regarding such motions on the record, regardless whether the motion is allowed or denied, to assist an appellate court in reviewing the determination on appeal." The direction seeks to prevent any abuse of discretion on the part of the judges.
