A Massachusetts court has reaffirmed the "Massachusetts rule" that "an individual whose property is damaged by an overhanging tree has no cause of action against a landowner of the property upon which the tree lies." Shiel v. Rowell, 2017 WL 3616892 (Mass. App. Div. 2017), citing Ponte v. DaSilva, 446 N.E.2d 77 (Mass. 1983). The court noted the contrary "Hawaii rule" that does make a tree owner financially responsible if her own trees overhangs neighboring property and damages it.