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Abstract: 

Our regular review of appellate court rulings surveys five important 2025 decisions addressing the scope, evidentiary standards, and constitutional limits of domestic violence protective orders. In Kentucky, the state supreme court held that courts may issue protective orders against nonresident abusers who flee-state victims seek protection from, finding that such orders fit within a “status” exception to personal jurisdiction and may include firearm restrictions and temporary custody provisions (Baum v. Aldava, 713 S.W.3d 96 (Ky. 2025)). In Washington, the court affirmed a domestic violence protection order grounded in coercive control, ruling that proof of the respondent’s intent to harm is unnecessary where conduct causes emotional or psychological injury (Timaeus v. Timaeus, 34 Wash. App. 2d 670 (Wash. Ct. App. 2025)). Arizona’s appellate court reversed an order where allegedly harassing communications were directed to a third party rather than the petitioner, clarifying limits on harassment-based relief (Hernandez v. Loarca, 571 P.3d 371 (Ariz. Ct. App. 2025)). North Dakota rejected reliance on a criminal self-defense statute to defeat a civil domestic violence protection order, emphasizing that criminal defenses do not extinguish civil remedies (Anderson v. Krueger, 26 N.W.3d 556 (N.D. 2025)). Finally, the Texas Supreme Court held that protective orders prohibiting parent-child contact for more than two years implicate fundamental parental rights and therefore require clear and convincing evidence and a best-interests analysis (Stary v. Etheridge, 712 S.W.3d 584 (Tex. 2025)). Collectively, these decisions illustrate courts’ ongoing efforts to balance victim safety, due process, coercive control, interstate enforcement, and constitutional protections in protective-order litigation.

Keywords: Orders of Protection; Domestic Violence Protective Orders; Coercive Control; Personal Jurisdiction; Due Process; Family Violence Litigation

Affiliations:  1: Contributing Editor; 2: Associate Editor.