Carrillo v. Carrillo

Robert Carrillo, Jr., appeals the trial court’s' entry of final- judgment of injunction for protection against domestic violence in favor of Sarah Jean Carrillo. The record in this case- reflects that the trial court, which also presided over three other cases involving the parties, relied primarily on non-record evidence from those cases to support the final judgment of injunction. We do not suggest that a trial court cannot rely on records from other cases involving the same parties to a subsequent injunction proceeding, but it must follow the procedure for taking judicial notice of those…