Allison N. Crowston, V. Ryan R. Cory, 86632-0

Allison Crowston filed for a Domestic Violence Protection Order (DVPO) against her former spouse, Ryan Cory, based on alleged past domestic violence during their marriage and recent unsettling encounters.
The marriage ended in 2015 following a series of abusive incidents, including physical harm, threats, and stalking by Cory.
Crowston reported continued mental and physical health issues as a result of the abuse and said Cory’s ex-partner informed her that Cory remained obsessed and had moved nearby.
In 2023, Cory twice attempted contact with Crowston, which she found intimidating given their history and made her feel unsafe.
The trial court acknowledged past domestic violence but denied the DVPO, citing the passage of time and lack of recent qualifying conduct, and Crowston appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court was required to issue a DVPO upon finding past domestic violence	Crowston: Statute requires DVPO upon a finding of past domestic violence; timing is irrelevant	Cory: Encounters in 2023 were benign; past actions should not mandate a current protection order	Held for Crowston; statute mandates issuance if past DV is proven
Whether the court improperly denied the DVPO based on the passage of time	Crowston: Statute prohibits denial based on time lapse since last incident	Cory: No recent harmful conduct justifying new order	Held for Crowston; passage of time is not a valid ground for denial
Whether recent conduct must independently constitute domestic violence for a DVPO	Crowston: Recent events are threatening in light of past abuse; order does not require recent violence	Cory: 2023 incidents do not qualify as violence or harassment	Held for Crowston; past violence and present fear are sufficient per statute
Whether additional risk assessment is needed before granting a DVPO	Crowston: Statute does not require further risk assessment if DV is found	Cory: Lack of evidence Cory knows Crowston’s location or is a risk	Held for Crowston; risk assessment not required beyond DV finding

Cox v. Fulmer, 31 Wn. App. 2d 485 (abuse of discretion standard for protection order decisions)
Maldonado v. Maldonado, 197 Wn. App. 779 (standard for review of DVPO denials)
In re Marriage of Chandola, 180 Wn.2d 632 (definition of abuse of discretion)
Rodriguez v. Zavala, 188 Wn.2d 586 (statutory interpretation principles)
Davis v. Arledge, 27 Wn. App. 2d 55 (petitioner need not show recent violence for DVPO)
Spence v. Kaminski, 103 Wn. App. 325 (timing of last domestic violence act not dispositive for DVPO)
Graser v. Olsen, 28 Wn. App. 2d 933 (standard for appellate review of protection order denials)
State v. Gray, 174 Wn.2d 920 (plain language statutory interpretation)