P.K.W. v. Steagall

"[I]t is appropriate to continue FAPA restraining orders when there is evidence of post-separation events that established a continuing threat to petitioner's safety." Hubbell v. Sanders, 245 Or App 321, 263 P3d 1096 (2011).

Respondent appealed an order continuing an ex parte restraining order under the Family Abuse Prevention Act (FAPA) after a contested hearing. On appeal, Respondent argued there was insufficient evidence for continuing the restraining order. In response, Petitioner presented evidence that Respondent had violated the restraining order twice, arguing this evidence satisfied the requirement that the Petitioner be in imminent danger of further abuse. "[I]t is appropriate to continue FAPA restraining orders when there is evidence of post-separation events that established a continuing threat to petitioner's safety." Hubbell v. Sanders, 245 Or App 321, 263 P3d 1096 (2011). The Court found that, in addition to the pending contempt charges for the Respondent's restraining order violation, the trial court's inferences were reasonable. Affirmed.