The Oregon Court of Appeals has affirmed a restraining order issued under the Family Abuse Prevention Act (FAPA), impacting the lives of those involved in domestic disputes. The ruling came on November 4, 2026, in the case of M. G. S. v. Odyne, docket number A188351. The court's decision emphasizes the importance of the legal definitions surrounding domestic relationships and the due process rights of individuals involved in such cases.

The case centers around a restraining order that was initially granted to M. G. S. against Odyne Odyne. Odyne, who represented herself in the appeal, argued that the trial court made errors in continuing the restraining order. She claimed that the parties did not have a qualifying relationship and that her due process rights were violated during the original proceedings. The court's ruling is significant for individuals navigating similar legal situations, as it clarifies the standards for establishing a qualifying relationship under FAPA.

The parties in this case are M. G. S. (the petitioner) and Odyne Odyne (the respondent). The dispute arose when M. G. S. sought a restraining order against Odyne, alleging abuse. The restraining order was issued following a contested hearing in the Multnomah County Circuit Court, where the judge found sufficient evidence to support M. G. S.'s claims. Odyne later appealed the decision, leading to the current ruling by the Oregon Court of Appeals.

The case reached the appellate court after Odyne Odyne filed her appeal, challenging the continuation of the restraining order. She contended that the trial court erred in its findings regarding the relationship between the parties and alleged violations of her due process rights. The court noted that M. G. S. did not appear on appeal, which limited the arguments presented to the court.

The Oregon Court of Appeals, in a per curiam decision, affirmed the trial court's ruling. The court stated, "The trial court did not plainly err in finding a qualifying relationship under FAPA." This finding was based on M. G. S.'s testimony that she and Odyne lived together in 2000. Odyne disputed this claim but did not provide any contrary evidence during the hearing. The court emphasized that the trial court was entitled to credit M. G. S.'s testimony over Odyne's assertions.

The court also addressed Odyne's claims of due process violations. It noted that she did not adequately argue how her constitutional rights were violated and merely used the term "due process" to encompass various procedural concerns. The court found no plain error in the trial court's handling of the case, stating, "The court could not counsel respondent on how to make objections or otherwise advise her on how to represent herself."

Furthermore, the court clarified that the trial court's evidentiary rulings were appropriate and focused on the relevant issues surrounding the restraining order. The court admitted evidence presented by Odyne and upheld the trial court's credibility findings. The appellate court reiterated that the trial court found, "petitioner established by a preponderance of evidence that he was subjected to abuse by respondent within the last 180 days, that he reasonably fears for his physical safety, and respondent represents a credible threat to his physical safety."

This ruling is important as it reinforces the standards for continuing a restraining order under FAPA. The court highlighted that the definition of "abuse" includes acts between family or household members, and that cohabitation does not have a strict time limit for consideration in such cases. The ruling clarifies that testimony alone can suffice as evidence in these matters, and the trial court's discretion in determining credibility is upheld.

The impact of this ruling extends to individuals involved in domestic disputes and those seeking protective orders. It underscores the necessity for clear evidence and testimony regarding relationships in cases involving restraining orders. Individuals facing similar situations may find guidance in this ruling, as it delineates the legal framework surrounding FAPA and the evidentiary standards required for establishing a qualifying relationship.

Looking ahead, the decision can potentially be appealed to the Oregon Supreme Court, although details regarding the likelihood of such an appeal were not available in the court filing. As of now, there are no related cases pending that have been mentioned in this ruling. The court's opinion serves as a reminder of the complexities involved in family law and the importance of understanding one's rights and the legal definitions that govern domestic relationships.