The Supreme Judicial Court of Massachusetts has held that the common law distinction between a licensee and an invitee is abrogated and that the standard of care owed by an occupier to a non-trespasser is to be decided by personal negligence criteria.
Mounsey v. Ellard, 297 N.E.2d 43 (Mass. 1973).
William T. Cullen,
Torts - Negligence - Licensee - Invitee - Standard of Care,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol12/iss4/12