Maise Qiaomei Chen, V. Hung Duy Le Aka Andrew Lee
86541-2
| Wash. Ct. App. | Jun 9, 2025Background
- Maisie Chen and Andrew Le had a romantic relationship starting in 2015, lived together with their two children in homes in Lynnwood and later Stanwood, Washington.
- While living in Stanwood, Le did not provide Chen a key to the house, limited her access to household areas, installed security cameras, and unilaterally deprived her of home internet access.
- Le also withheld access to certain items (children's clothing) and refused to make Chen a key unless she gave him her car key, leading to situations where Chen and the children were unable to enter their home.
- Chen alleged these actions severely restricted her autonomy and constituted coercive control, prompting her to seek a domestic violence protection order for herself and her children.
- The superior court commissioner found a pattern of coercive control, granted the protection order, and Le appealed, arguing insufficient evidence supported the findings.
- On appeal, the court reviewed the commissioner’s factual findings under a substantial evidence standard, with all reasonable inferences drawn in favor of Chen as the prevailing party.
Issues
| Issue | Chen's Argument | Le's Argument | Held |
|---|---|---|---|
| Did substantial evidence show coercive control? | Le’s pattern of behavior caused emotional harm and interfered with her liberty. | His actions were not intended to control, and some failures were oversights. | Yes; Le’s actions constituted coercive control under the statute. |
| Was there an unreasonable interference with Chen's liberty? | Denial of house key, surveillance, and restricted access limited her free will. | She did not need a key and there was no intent to control. | Yes; restricted freedom unreasonably interfered with her liberty. |
| Did the commissioner properly apply the statutory standard? | Commissioner properly found a pattern of conduct per statute. | Commissioner failed to make specific credibility findings. | Yes; record supported findings regardless of explicit credibility findings. |
| Should Chen be awarded attorneys’ fees on appeal? | Requested under RAP 18.9(a) and RCW 7.105.310(1)(j). | Opposed, as not properly supported. | No; fee request denied as not properly analyzed or supported. |
Key Cases Cited
- Nguyen v. City of Seattle, 179 Wn. App. 155 (Wash. Ct. App. 2014) (substantial evidence standard for review of factual findings)
- In re Estate of Langeland, 177 Wn. App. 315 (Wash. Ct. App. 2013) (substantial evidence is that which persuades a fair-minded, rational person)
- Korst v. McMahon, 136 Wn. App. 202 (Wash. Ct. App. 2006) (all reasonable inferences viewed in favor of prevailing party)
- In re Marriage of Rideout, 150 Wn.2d 337 (Wash. 2003) (appellate court may affirm on any basis supported by the record)