Parris J. V. Christopher U.

February 15, 2024

In this case, Parris got a five-year DVRO against her former husband Christopher, and an award of $200,000 attorney’s fees under the DVPA.  The trial court also denied Christopher’s two requests for a Statement of Decision.  The Court of Appeal affirmed, concluding the trial court correctly found the evidence showed Christopher had abused Parris in many ways, including financial abuse, threats, coercive control, harassment, and disturbing the peace.  Plus, Christopher violated Parris’s TRO by sending disparaging letters to her new employer, trying to get her fired.  Further, the Court concluded Christopher’s Statement of Decision requests were improperly made, so properly denied.  And since the Court was affirming the DVRO, there was no basis to reverse Parris’s attorney’s fees award.

Importantly, this case has some relatively novel holdings and conclusions.  First, this is one of the first cases to discuss “coercive control” in a context without physical abuse—here Christopher monitored and controlled Parris’s movements and communications, ran up her debt, and threatened to destroy her property.

Second, this case explains courts should focus on the survivor’s perspective and experience- not a “reasonable person” or “objective” standard- when  analyzing “disturbing the peace of the other party” and “harassment” under the DVPA.

Third, this is the first case to explain that having a large life insurance policy on someone’s life can “disturb the peace” of that person. Especially given the extensive abuse Christopher subjected Parris to, it was legally sound for the trial court to find that his benefitting from an insurance policy on her life “disturbed Parris’s peace” under the law.

Fourth, this is the first case to explain that the trial court could legally order an abuser (Christopher) to change the beneficiary of that insurance policy on the survivor’s (Parris’s) life.

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