Hart v. Hart (2025) 115 Cal.App.5th 571

Case
February 4, 2026
Description

In this case the trial court renewed a DVRO for only 9 months. The protected party appealed arguing that a five-year period was the minimum allowed by the DVPA. Finding that the trial court does not have discretion under Family Code section 6345 to renew a DVRO for a period of less than 5 years, the Court of Appeal agreed. Noting that the plain language of the DVPA states that a DVRO “may be renewed…either for five or more years, or permanently”, the Court of Appeal reversed the order and instructed the trial court to issue a five-year renewal.

Abuse
Restraining Orders

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