371 Mass. 714, 358 N.E.2d 817 (Mass. 1977)
Blackett v. Olanoff is a foundational Massachusetts Supreme Judicial Court decision on constructive eviction and the covenant of quiet enjoyment.
Whether tenants are constructively evicted and relieved of their rent obligations when substantial, recurring noise emanates from a lounge that the landlord leased and could control, even if the landlord did not personally intend to disturb the tenants and the activity is carried out by another tenant.
A landlord breaches the covenant of quiet enjoyment and constructively evicts a tenant when the landlord's conduct—or the conduct of third parties acting under the landlord's authority or control—substantially interferes with the tenant's use and enjoyment of the premises, and the interference is the natural and probable consequence of the landlord's leasing arrangements or omissions. Intent to disturb is not required; foreseeability and the landlord's ability to prevent or abate the interference are central. If the interference renders the premises unsuitable for their intended use and the tenant vacates within a reasonable time, the tenant is relieved of the obligation to pay rent from the time of constructive eviction.
Yes. The court held that the tenants were constructively evicted. The substantial nighttime noise was the natural and probable consequence of the landlord's leasing of adjacent premises to a lounge and his failure to control it, thereby breaching the tenants' covenant of quiet enjoyment and relieving them of rent after they vacated.
Blackett v. Olanoff is a leading case on constructive eviction that teaches three key lessons. First, landlord intent is not required; foreseeability and control are the touchstones. Second, acts of third parties—such as commercial tenants—can be attributed to the landlord when the landlord's leasing decisions and retained authority make the interference a natural and probable result. Third, substantial, recurring interference with residential use (e.g., persistent nighttime noise) can constitute constructive eviction if the tenant vacates within a reasonable time. For law students, Blackett contextualizes quiet enjoyment alongside nuisance and the implied warranty of habitability, showing how doctrinal lines interact in practice and how remedies like termination of rent obligations become available when conditions are intolerable.