Civil Protection Order

Washington Court Upholds Anti-Harassment Protection Order Against Neighbor Who Directed Employees to Harass

April 28, 2026 | by Blair Kim Moeller, PLLC

When does a neighbor dispute cross the line into unlawful harassment—and what can a court do about it? In Perkins v. Jensen, No. 88080-2-I (Wash. Ct. App. April 27, 2026), the Washington Court of Appeals, Division One, affirmed an anti-harassment protection order against a construction company co-owner whose employees engaged in a pattern of deliberate harassment against a neighboring homeowner in Snohomish County. The decision addresses several important questions about how anti-harassment protection orders work under Washington’s protection order statute, chapter 7.105 RCW.

If you are dealing with harassment from a neighbor, a business, or any other person, the attorneys at Blair & Kim can help you understand your legal options. Contact us for a confidential case evaluation.

What Happened in Perkins v. Jensen?

Types of Protection Orders in Washington

April 6, 2026 | by Blair Kim Moeller, PLLC

Washington law provides several types of civil protection orders designed to protect people from violence, harassment, stalking, and abuse. Since July 1, 2022, all of these orders are governed by a single statute—chapter 7.105 RCW—which consolidated what had previously been scattered across multiple chapters of the Revised Code of Washington. Whether you are considering seeking a protection order or have been served with one, understanding the different types and how they work is an important first step.

The attorneys at Blair & Kim handle protection order cases for both petitioners and respondents throughout King, Pierce, and Snohomish Counties. Contact us for a confidential case evaluation.

The Six Types of Protection Orders in Washington

Washington Court Affirms Domestic Violence Protection Order: No Intent Requirement, No Detailed Findings Needed

March 19, 2026 | by Blair Kim Moeller, PLLC

Domestic violence protection orders can reshape every aspect of a family’s life—restricting contact with a spouse, limiting time with children, and creating a record that follows the respondent for years. In In re Marriage of Sheridan, No. 87948-1-I (Wash. Ct. App. March 16, 2026), the Washington Court of Appeals, Division One, affirmed a DVPO and clarified two important points about how these orders work under Washington’s protection order statute, chapter 7.105 RCW. For anyone involved in a civil protection order proceeding in the Seattle area, this decision matters.

Whether you are seeking a protection order or defending against one, the attorneys at Blair Kim Moeller, PLLC can help you navigate the process. Contact us for a confidential case evaluation.

What Happened in Sheridan?

Washington Appeals Court Affirms Vulnerable Adult Protection Order

December 21, 2025 | by Blair Kim Moeller, PLLC

In most cases, a person protected by a Washington civil protect order wants the order and limitations it provides. A vulnerable adult protection order, however, is commonly sought by someone else on behalf of the vulnerable person, and in some cases, the allegedly vulnerable person may object to the order. In a recent unpublished case, a man recently challenged a vulnerable adult protection order issued against him.

The petitioner sought a vulnerable adult protection order as attorney for a woman who was over 80 years old and had dementia and other health issues. She alleged the respondent had “abandoned, abused, financially exploited, or neglected” the woman, identifying specific incidents. The petition alleged the respondent had taken the woman from her retirement community to her former home twice, which upset her when she learned the place had been rented. The petitioner also alleged the respondent had given the woman alcohol twice when he was aware she had issues with alcohol abuse. The petitioner provided declarations from herself, the woman’s brother, another of the woman’s relatives, and an agent with a durable power of attorney.

The respondent submitted his own declaration, transcripts of calls with the woman, and two character reference letters.

Washington Court Allowed to Correct Expiration Date of DVPO as Clerical Error

September 11, 2025 | by Blair Kim Moeller, PLLC

A Washington protection order generally must state the date when it expires. If the order is to be permanent, the court should set its expiration date at 99 years from the date it is issued. RCW 7.105.310(5). A former wife recently appealed an order purportedly clarifying the expiration date of a renewal of a domestic violence protection order (“DVPO”) against her former husband.

According to the unpublished opinion of the appeals court, the ex-wife moved to renew a DVPO against her ex-husband in November 2023. She indicated she wanted the order to remain in effect “permanently” and asked the court to renew the order for the “maximum period allowed by law.” She described ongoing communication and contact by the ex-husband. The ex-husband denied the allegations and asked the court to deny the renewal.

The ex-wife and her attorney appeared in person at the hearing, while the husband and his attorney appeared by video conference. The court granted the renewal motion. The body of the renewal order did not identify the expiration date. Instead, there was a line in the caption of the order that stated: “Renewal Expires: 11/21/2122.”

Washington Appeals Court Holds Weapons Surrender Statute Constitutional

July 22, 2025 | by Blair Kim Moeller, PLLC

The Fifth Amendment to the U.S. Constitution and article 1, section 9 of the Washington State Constitution both protect an individual’s right against self-incrimination. A person may, however, be compelled to answer if they are protected from the use of their answers and evidence derived from them in any subsequent criminal case against them. State v. King. A former husband recently challenged the constitutionality of the Washington weapons surrender statute under the Fifth amendment and other constitutional protections after a court found him to be non-compliant with a weapons surrender order.

The parties divorced in April 2022. The trial court issued a temporary domestic violence protection order (“DVPO”) requiring the ex-husband to surrender his firearms after the divorce. The ex-husband and his friend claimed his firearms were being stored at the friend’s house.

The ex-wife identified several additional weapons the ex-husband owned during the marriage in her declaration. The court issued a DVPO for one year and a new surrender order that listed the firearms identified in the ex-wife’s declaration.

Washington Appeals Court Upholds Court’s Decision Not to Realign Parties in DVPO Case

May 19, 2025 | by Blair Kim Moeller, PLLC

RCW 7.105.225(1)(a) requires a court to issue a Washington domestic violence protection order (“DVPO”) if the petitioner proves, by the preponderance of the evidence, they have been the subject of domestic violence committed by the respondent. “Domestic violence” includes “[p]hysical harm, bodily injury, assault, or the infliction of fear” thereof. RCW 7.105.010(9). RCW 7.105.210 allows the court to “realign the designation of the parties” in a proceeding involving a DVPO or antiharassment protection order if it finds the original petitioner was the abuser or harasser and the original respondent was the victim. The court may then issue a temporary protection order to allow the victim an opportunity to file their own petition.

In a recent unpublished case, the trial court declined to realign the parties and issue a DVPO protecting the husband, and he appealed. According to the opinion, the wife had petitioned for legal separation in 2023 after about ten years of marriage. She subsequently petitioned for a DVPO to restrain the husband from contacting her and the children. She alleged she was concerned about his alcohol and drug use and that she was “very much afraid” of him when he was under the influence.

She also alleged that he had thrown her into a door in January 2020. She also said that he struck her in the face and pushed her down when she confronted him about his substance use in May 2022, while the children were in the adjoining room. She submitted photographs of her injuries. She also described an incident in which the husband yelled at one of the children and blamed him for a college football team’s loss.

Washington Appeals Court Affirms Denial of DVPO Based on Insufficient Evidence

February 21, 2025 | by Blair Kim Moeller, PLLC

Washington civil protection order proceedings are sometimes related to family law issues. In a recent case, a mother appealed a court’s denial of a second protection order after her divorce.

According to the appeals court’s unpublished opinion, the father had repeatedly assaulted the mother during her pregnancy with their child. After the birth, he threatened to kill the mother, the child, and himself. The parties divorced in 2012 and the parenting plan provided that the father’s visitation with the child was to be professionally supervised. The father wanted additional visitation with the child in 2015. According to the opinion, he went into the mother’s home and demanded visitation and refused to leave. The mother then obtained a restraining order for five years against the father. The child started seeing a therapist.

In 2018, the child and the father started court-ordered reunification counseling.

Washington Appeals Court Overturns Felony Violation of A Court Order Conviction

December 7, 2024 | by Blair Kim Moeller, PLLC

Pursuant to RCW 7.105.450(1)(a), a violation of a Washington domestic violence protection order is generally a gross misdemeanor. A violation can be a felony, however, if it constitutes an assault “that does not amount to assault in the first or second degree.” RCW 7.105.450(4). In a recent unpublished case, a Washington appeals court considered whether a defendant can be convicted of both a felony violation of a no contact order under RCW 7.105.450(4) and assault in the second degree under RCW 9A.36.021(1)(a) for the same acts.

An April 2022 no contact order prohibited the defendant from having contact with the protected person, identified by the appeals court as “C.S.,” or coming within 1,000 feet of her or her residence for 10 years.

According to the court’s opinion, C.S. called 911 in September 2022. She said the defendant had been staying with her and had kicked and “beat [her] up.” She said she had refused to give him a cigarette and he tried to steal her purse. She said there was a struggle when she grabbed it back and he punched her and knocked out her tooth. She said he kicked her and dragged her over rocks.

Washington Appeals Court Affirms DVPO Based on Unlawful Harassment

November 21, 2024 | by Blair Kim Moeller, PLLC

In a petition for a Washington domestic violence protection order (“DVPO”), the court shall issue the protection order if it finds “the petitioner has been subjected to domestic violence by the respondent.” RCW 7.105.225. Domestic violence includes unlawful harassment. Unlawful harassment is “[a] knowing and willful course of conduct . . . that seriously alarms, annoys, harasses, or is detrimental to such person, and that serves no legitimate or lawful purpose.” The course of conduct must cause actual substantial emotional distress and must be conduct that would cause substantial emotional distress to a reasonable person. RCW 7.105.010. The definition statute identifies the factors to be considered in determining if a course of conduct has a legitimate or lawful purpose, including: who initiated contact, whether there has been clear notice contact is unwanted; whether the “course of conduct appears designed to alarm, annoy, or harass the petitioner”; whether the respondent is acting under statutory authority; whether the course of conduct’s purpose or effect is to unreasonably interfere with the privacy of the petitioner or “creating an intimidating, hostile or offensive living environment”; and whether a previous court order has limited the respondent’s contact with the petitioner or their family. RCW 7.105.010(6).

In a recent unpublished opinion, an ex-wife challenged a DVPO protecting her former husband. The former wife had remarried, and according to the former husband, the parties began having difficulty co-parenting in 2021.

The ex-husband sought a DVPO in May 2023. He attached texts and emails, alleging the former wife had been abusively targeting him electronically. His fiancée stated in her declaration that the ex-wife had chased them through a parking lot when they were leaving an event for the child. The ex-husband asked that the ex-wife be required to surrender her firearms.