G.G. v. G.S.

G.G. got a two-year DVRO against her former cohabitant and father of their children, G.S., for his abuse of her that included blocking her, recording her, harassing her, taking her phone, and stalking her on over 70 occasions. The trial court denied G.G.’s request to renew her DVRO, noting that G.S. had not violated the restraining order. The appellate court reversed, for two key reasons. First, the abuse that led to G.G.’s original DVRO was severe, even if not significant physical abuse. The underlying abuse itself, then, supported renewing the DVRO.  Second, DVRO renewal could be warranted here, even if G.S. had not violated the order.  Significantly, the opinion focuses on the dangerousness, risks, and severity of stalking abuse, and the significant impacts it can have on survivors.

Statutes used or affected: Fam. Code, §§ 6203, 6320, 6345