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Amanda Helen Taylor v. Todd Emory Taylor
39380-1
Wash. Ct. App.
Feb 6, 2024
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Background

  • Amanda Taylor filed for a domestic violence protection order against her ex-husband, Todd Taylor, following the dissolution of their marriage.
  • Amanda alleged Todd engaged in coercive control, verbal and emotional abuse, financial exploitation, and occasional threats or physical aggression, impacting both herself and their two children.
  • Todd denied the allegations, asserting no ongoing danger and pointing to limited contact since the divorce, as well as a lack of findings or restraining orders in earlier proceedings.
  • The trial court denied the protection order, citing lack of corroborating, extrinsic evidence beyond the parties' conflicting declarations and communications.
  • Amanda appealed, challenging the court’s credibility assessment, its interpretation of the legal standard for coercive control, and the refusal to review case law she offered.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Credibility Findings Court wrongly credited Todd, ignored evidence of a pattern of coercive control Disputes all allegations, highlights lack of corroborating evidence Deference to trial court’s credibility findings; no error
Legal Standard for Coercive Control Court required undue objective evidence, not just patterns and impact Court followed correct standard; no new facts or proven harm Court applied correct preponderance standard
Consideration of Plaintiff’s Case Law Court erred in refusing to review and cite helpful case law No requirement to accept or cite proffered cases at hearing No error; court not required to accept or cite parties' cases
Use of Prior Proceedings Court erred by considering lack of earlier protection orders as negative Proper to consider entire procedural history without prior findings Trial court could properly consider lack of earlier findings

Key Cases Cited

  • In re Knight, 178 Wn. App. 929 (2014) (appellate courts defer to trial courts on factual and credibility determinations)
  • State v. Nguyen, 10 Wn. App. 2d 797 (2019) (concerns sufficiency of evidence for felony stalking; not dispositive here)
  • State v. Abdi-Issa, 199 Wn.2d 163 (2022) (addressed animal cruelty as a form of domestic violence)
  • State v. Becklin, 163 Wn.2d 519 (2008) (statutory interpretation of stalking statute)
Read the full case

Case Details

Case Name: Amanda Helen Taylor v. Todd Emory Taylor
Court Name: Court of Appeals of Washington
Date Published: Feb 6, 2024
Docket Number: 39380-1
Court Abbreviation: Wash. Ct. App.