G.G. v. G.S.

Survivor 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 in particular that G.S. had not violated it.  The appellate court reversed, explaining two key holdings.  First, the abuse that led to G.G.’s original DVRO was severe, even if not significant physical abuse, so the underlying abuse itself can support the renewal.  Second, DVRO renewal could be warranted here, even if no violations occurred.  The opinion focuses in particular on the dangerousness, risks, and severity of stalking abuse, and the significant impacts it can have on survivors.