The Massachusetts Supreme Judicial Court has reaffirmed the "Massachusetts rule" that owners cannot sue their neighbors for any damage caused by an overhanging healthy tree. Shiel v. Rowell, 101 N.E.3d 290 (Mass. 2018). The remedy is for the owner to trim the branches that encroach on his property before they cause damage. In upholding the established rule, the court rejected the "Hawaii rule" which imposes liability on the owner of the tree if it causes harm to neighboring property. See Whitesell v. Houlton, 632 P.2d 1077 (Haw. 1981). Note that the Massachusetts rule does impose an obligation on owners to remove unhealthy trees and imposes liability for any harms to neighbors caused by such trees.