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Name: Parris J. v. Christopher U. (2023) 96 Cal.App.5th 108
Case #: B313470; B316247; B317613
Court: CA Court of Appeal
District 2 DCA
Division: 4
Opinion Date: 10/04/2023

Substantial evidence supported the issuance of a Domestic Violence Restraining Order (DVRO) because the Domestic Violence Prevention Act (DVPA) encompasses behavior which amounts to “coercive control.” Three months after Parris and Christopher were married, Parris moved her things out of their house after Christopher threatened to dispose of her belongings following an argument. After Parris moved, Christopher arrived uninvited to Parris’s apartment and would not allow Parris to leave until her friends arrived and escorted her out. Christopher sent Parris many lewd and demeaning emails and texts until Parris told him to stop contacting her. The trial court granted Parris a DVRO and Christopher appealed. The reviewing court affirmed. The DVPA definition of domestic violence includes “disturbing the peace of the other party” which refers to conduct that destroys the mental or emotional calm of the other party. The court rejected Christopher’s argument that it must apply an objective, reasonable person standard. The relevant inquiry is whether the person against whom the DVRO is sought engaged in conduct that destroyed the mental or emotional calm of the other party. Here, Christopher used a combination of financial and emotional abuse to overcome Parris’s will and subdue her into doing what he wanted. Christopher’s disparaging text messages rose to the level of threats against Parris and her family. Additionally, he threatened to sue Parris for the cost of their wedding and ruin her financially. Further, Christopher sued Parris’s father in response to her request for a DVRO and sent disparaging letters to Parris’s employer. These actions support a finding that Parris was a victim of “coercive control” and thus, substantial evidence supported the issuance of the DVRO.