Case Alert: Michael M. v. Robin J. (2023)

(1) Renewing a DVRO does not require the survivor to show recent abuse or violations of the restraining order.

(2) Fear of future abuse can be shown by old violent conduct, and also by recent non-violent conduct.

(3) The survivor's motive for seeking DVRO renewal is not relevant - an angry or hostile survivor is still entitled to DVRO renewal if s/he has a reasonable fear of future abuse.