J.J. v. M.F., 223 Cal. App. 4th 968

J.J. obtained a DVPA restraining order against M.F. in Sept 2011 for herself and their son; TRO entered and a three-year order issued after a hearing.
M.F. had a history of violence against J.J., including pushing her from a car, pushing through a glass door, choking, and threats to harm her.
M.F. sought to set aside the order in Jan 2012, claiming lack of notice; J.J. did not appear at that hearing.
In Oct 2012, J.J. filed an ex parte application for a restraining order based on an Oct 7, 2012 incident; M.F. filed a response.
The court held a hearing in Oct/Nov 2012, treated the Oct 7 incident as a mutual altercation, and issued a mutual restraining order against both parties.
J.J. appeals to challenge the mutual order against her; the appellate court reverses to the extent the order restraining J.J. is issued, affirming the rest of the ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a mutual DVPA order was properly issued against J.J.	J.J. argues she did not act primarily as aggressor; order was not supported by §6305 standards.	M.F. contends the mutual order was appropriate given both parties' aggression.	Reversed as to J.J.; no substantial evidence she acted primarily as aggressor.

S.M. v. E.P., 184 Cal.App.4th 1249 (Cal. Ct. App. 2010) (review of DVPA abuse of discretion and substantial evidence standards)
Conness v. Satram, 122 Cal.App.4th 197 (Cal. Ct. App. 2004) (DVPA mutual order statutory requirements 6305 considerations)
Sabbah v. Sabbah, 151 Cal.App.4th 818 (Cal. Ct. App. 2007) (substantial evidence standard for mutual restraining order findings)
Vaughn v. Jonas, 31 Cal.2d 586 (Cal. 1948) (self-defense and reasonable force principles applied to restraining order context)