Whalen v. Whalen

STOWERS, Chief Justice.

I. INTRODUCTION

Sarah and Sean Whalen's relationship had been plagued by domestic violence prior to the incidents involved in this appeal. Sarah had petitioned for multiple domestic violence protective orders against Sean, some of which had been granted. In November 2015 Sarah filed a petition for a long-term domestic violence protective order against Sean. The superior court ruled that she could not rely on Sean's past history of domestic violence alone to obtain a new protective order but had to show that Sean had committed a new incident of domestic violence since the…