Maffey v. Muchka, 261 P.3d 26

Maffey and Muchka had an ~18‑month relationship and a child together; respondent’s PTSD contributed to volatile conduct.
Easter 2010 incident: Muchka became angry, chased Maffey, shoved her against a wall, and she fled; she feared imminent harm.
Thanksgiving 2009 incident: Muchka similarly pushed Maffey against a wall and threatened her.
Maffey filed for a restraining order, leading to a temporary order and a hearing on continuation.
Trial court credited Maffey’s credibility, found abuse during the Easter incident, and concluded a pattern of intimidation and control supported imminent danger.
Respondent allegedly violated the temporary order by approaching the safe house and having a friend contact Maffey.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there abuse within 180 days before filing?	Maffey argues Muchka placed her in fear of imminent bodily injury.	Muchka contends the evidence does not prove abuse within 180 days.	Yes; evidence sufficed to show recklessly placing in fear of imminent injury.
Was there imminent danger of further abuse?	Maffey asserts a continuing pattern of controlling behavior and escalating threats.	Muchka argues no proven imminent threat beyond the past incidents.	Yes; past pattern and ongoing threats established imminent danger.
Did the trial court err in credibility determinations or evidentiary standards?	Maffey contends trial court properly credited her testimony and behavior as reliable.	Muchka challenges the sufficiency of credibility assessment.	No error; findings supported by credible testimony and evidence.

Fielder v. Fielder, 211 Or.App. 688 (Or. App. 2007) (pattern of abuse supports restraining order when imminent danger shown)
Rosiles-Flores v. Browning, 208 Or.App. 600 (Or. App. 2006) (continued abuse and attempts to contact support issuance of order)
State v. B.B., 240 Or.App. 75 (Or. App. 2010) (pattern of abuse and imminent danger considerations reviewed on appeal)