Knopik v. Hahn, 902 N.W.2d 716

On Oct. 14, 2016, an on‑foot encounter occurred in front of Knopik and Greenwood’s home when their new unleashed dog approached Hahn’s leashed dog; the encounter lasted 10–20 minutes.
Knopik testified Hahn yelled, used profanity, followed her onto the property, and made her fear for her and her child’s safety.
Greenwood testified he intervened, Hahn lunged at Greenwood, grabbed his sweatshirt, and punched him in the chest several times causing bruising.
Knopik and Greenwood filed ex parte harassment protection petitions under Neb. Rev. Stat. § 28‑311.09; ex parte orders issued the same day and were continued after a combined hearing.
At the Nov. 14, 2016 hearing, Knopik and Greenwood testified; Hahn presented no evidence. The district court found a “course of conduct” and extended the protection orders for one year.
On appeal, Hahn challenged whether the conduct met the statutory definition of a harassing “course of conduct.” The Court of Appeals reversed and directed vacatur of the orders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hahn’s single 10–20 minute confrontation constitutes a statutory “course of conduct” for harassment protection orders	Knopik/Greenwood: the incident involved a series of acts (yelling, following, name‑calling, physical assault) occurring “over a period of time, however short,” showing continuity of purpose	Hahn: the episode was an isolated, one‑time incident, not the repeated or stalking‑type conduct the statute targets	Court: Reversed—single, short incident without prior or subsequent similar acts did not satisfy the statutory “course of conduct” requirement

Richards v. McClure, 290 Neb. 124 (discussing de novo review of protection orders)
Torres v. Morales, 287 Neb. 587 (appellate de novo review may give weight to trial judge's credibility findings when evidence conflicts)
Glantz v. Daniel, 21 Neb. App. 89 (affirming dismissal where insufficient evidence of intimidating course of conduct)
State ex rel. Counsel for Dis. v. Lopez Wilson, 262 Neb. 653 (harassment order after multiple occasions of harassment)
Yancer v. Kaufman, 22 Neb. App. 320 (harassment order based on continual harassing conduct)
Linda N. v. William N., 289 Neb. 607 (stalking defined by ongoing, escalating conduct showing intent to intimidate)
In re Interest of Jeffrey K., 273 Neb. 239 (discussion of continuity and pattern in stalking/harassment context)
Mahmood v. Mahmud, 279 Neb. 390 (reversing protection order where statutory definition unmet)
Sherman v. Sherman, 18 Neb. App. 342 (reversing where insufficient evidence of course of conduct)