E.W. v. T.W.

Citations

• 2017 Ohio 8504

Syllabus

Trial court erred as a matter of law in determining that a threat received months earlier equated to domestic violence to support granting petitioner's CPO without first considering whether petitioner was placed in fear of imminent serious physical harm by a threat of force. Remand rendered respondent's assignment of error challenging adequacy of CPO hearing moot. Judgment reversed and cause remanded with instructions.