Personal protection order (PPO); Former spouse; MCL 600.2950; Reasonable cause; MCL 600.2950(4); Reasonable apprehension of violence; MCL 600.2950(1)(l); Stalking; MCL 750.411h; MCL 750.411i; Totality of circumstances; PF v JF; Motion to terminate PPO; Hayford v Hayford

The court held that the trial court did not abuse its discretion by denying respondent’s motion to terminate the PPO entered in petitioner’s favor. The parties were former spouses. Petitioner alleged that respondent produced a firearm while they were alone, entered her home without permission, and later slashed two tires on her boyfriend’s truck while it was parked in her driveway. On appeal, the court held that sufficient evidence supported continuation of the PPO under MCL 600.2950(1)(l) because that provision covers conduct “that causes a reasonable apprehension of violence.” The court reasoned that petitioner identified respondent in a video taken shortly after she discovered the slashed tires, was “frightened to learn that respondent was at her home with a weapon at night,” and the trial court believed her allegation. The court also rejected respondent’s argument that petitioner had to show stalking-like repeated conduct because he “erroneously applies these requirements to all conduct under MCL 600.2950(1).” The court explained that “[n]o such requirement exists,” so petitioner did not have to show another instance of harassment or a “continuity of purpose.” Affirmed.