La Valle v. La Valle, 69 A.3d 1

In May 2006 Janet La Valle obtained a final domestic violence protective order against her husband Lawrence La Valle, effective until October 10, 2006, granting her possession of the marital home and custody of the minor child.
On September 14, 2006 (before expiration), Janet filed a motion under FL § 4-507(a) to extend the protective order; the hearing was scheduled for October 3, 2006 — two days after the order expired.
At the October 3, 2006 hearing the District Court extended the protective order until March 1, 2007; the Circuit Court affirmed on de novo review, holding a timely-filed motion satisfied the statute even if the hearing occurred after expiration.
Lawrence appealed; the case reached the Maryland Court of Appeals on certiorari. The Court treated the case as presenting a recurring public concern and addressed the merits despite mootness.
The core legal question: whether FL § 4-507(a) allows extension of a protective order when the motion to extend was filed during the order’s term but the hearing and extension occur after the order expired.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 4-507 permits extending a protective order if the motion is filed during the order's term but the hearing occurs after expiration	La Valle: statute requires modification/extension "during the term"; untimely extension invalid; extension cannot relate back	La Valle (respondent): filing during the term suffices; hearing may occur after expiration; reading should avoid forcing victims to track scheduling	Court: Extension is a modification; § 4-507(a)(1) requires notice and a hearing "during the term"; an expired order cannot be extended even if motion was timely filed

Torboli v. Torboli, 365 Md. 52, 775 A.2d 1207 (2001) (held modification or rescission must occur during the term of the order)
Coburn v. Coburn, 342 Md. 244, 674 A.2d 951 (1996) (explains remedial/preventive purpose of domestic violence statute)
State v. Ficker, 266 Md. 500, 295 A.2d 231 (1972) (mootness doctrine principles)
Suter v. Stuckey, 402 Md. 211, 935 A.2d 731 (2007) (mootness exception for recurring public concerns)
Office of the Public Defender v. State, 413 Md. 411, 993 A.2d 55 (2010) (application of mootness exceptions)
Lloyd v. Bd. of Supervisors of Elections of Baltimore Cnty., 206 Md. 36, 111 A.2d 379 (1954) (factors for deciding moot but recurring issues)
Barbee v. Barbee, 311 Md. 620, 537 A.2d 224 (1988) (statutory purpose: immediate and effective protection for domestic abuse victims)