Herbert Jackson v. Patricia Jackson, 01-14-00952-CV

Patricia Jackson sought a protective order after several incidents with her husband, Herbert Jackson, culminating in August 2014.
May 18, 2014: At an airport Herbert verbally abused Patricia, threatened to "bust her in the face," and accused her of talking to another man.
July 2014: Herbert brought Patricia to his house, took her car keys and phone, refused to return the keys, pressured her about their marriage, and demanded sex in exchange for returning keys.
August 18, 2014: Herbert appeared at Patricia's home at 3:30 a.m., demanded sex, entered the house (allegedly through a storm door he later tore off), persistently rang/knocked and called, and frightened Patricia into calling police; officers told Herbert he was trespassing and ordered him to leave.
Patricia filed for a protective order on August 25, 2014; the 328th Judicial District Court granted relief on September 23, 2014. Herbert's motion for new trial was denied.
On appeal, Patricia (appellee) argues the trial court's finding of family violence was supported by legally and factually sufficient evidence and that the court did not abuse its discretion; she notes photographic evidence (including a ripped storm door photo) was admitted without objection at trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was legally and factually sufficient to find family violence	Jackson contends testimony and admitted photos (door) establish threats, forced entry, sexual coercion, and past abuse supporting family-violence finding	Herbert argued some attached photos were unrelated/"padded" and denied their accuracy; disputes evidence	Trial court's finding of family violence was supported; appellee argues evidence was sufficient and photos used at trial supported the finding
Whether trial court abused its discretion in issuing protective order	Jackson argues court acted within law, considering prior admitted history and inference of future abuse	Herbert contends evidence/pictures relied on were inappropriate or inaccurate, implying error in exercise of discretion	Appellee maintains no abuse: court applied guiding law and could infer future danger from past abusive conduct

In re Doe, 19 S.W.3d 249 (Tex. 2000) (standard for appellate review of family-violence protective orders)
Vongontard v. Tippitt, 137 S.W.3d 109 (Tex. App.—Houston [1st Dist.] 2004) (appellate review standards)
Boyd v. Palmore, 425 S.W.3d 425 (Tex. App.—Houston [1st Dist.] 2011) (definition of family-violence conduct and fear standard)
In re Epperson, 213 S.W.3d 541 (Tex. App.—Texarkana 2007) (past abuse permits inference of future abusive conduct)
Celestine v. Dep’t of Family & Protective Servs., 321 S.W.3d 222 (Tex. 2010) (abuse-of-discretion review principles)