Marriage of Glines CA3, C100488

Appellant Mary Anne Glines sought a domestic violence restraining order against Respondent Scott Glines on December 28, 2022; a temporary restraining order was issued the same day.
The trial court continued the TRO hearing multiple times, with a December 14, 2023 trial at which both sides testified about the request for a DVRO.
The court found no reasonable connection between Appellant’s distress and Respondent’s conduct, concluding there was no abuse or domestic violence under the Family Code and vacating the TRO.
Appellant submitted a proposed settled statement for the December 14, 2023 trial; the court noted there was no court reporter or detailed notes and that its own summary mirrored the order, and neither party objected or requested a hearing.
On appeal, Appellant challenges the settled statement, asserts coercive control should have been considered as abuse, and claims broader procedural unfairness in the trial and settled-statement process.
The appellate court affirmed the trial court’s order denying the DVRO after concluding the record was insufficient to review the asserted errors and that coercive control was a form of domestic violence but the court did not find reversible error in this case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of the settled statement	Glines argues the settled statement contains irregularities in her testimony/evidence.	Court has broad discretion to approve/reject proposed statements; no per se error in rejection.	No reversible error; settled statement affirmed.
Record sufficiency for appeal	There is no compliant settled statement or trial transcript to understand the appeal.	Record shows the court considered all evidence; lack of transcript does not establish reversible error.	Record inadequate to review key issues; cannot review the factual finding of abuse.
Coercive control as abuse under DVRO	Trial court failed to consider coercive control as a basis for DVRO under Fam. Code § 6320.	Coercive control is a form of domestic violence; the court could deny the DVRO if evidence does not establish abuse.	Coercive control is a form of DV; court presumed to understand law; no reversible error found on this basis.
Potential alternative orders under DVRO	Court could have granted ancillary orders (property, debts, child support) pending dissolution.	But not necessarily required; court may reserve such issues for later dissolution proceedings.	Appellant failed to show reversible error by not issuing ancillary orders.

Hotels Nevada, LLC v. L.A. Pacific Center, Inc., 203 Cal.App.4th 336 (2012) (judgment presumed correct; burden on appellant to show reversible error)
Del Real v. City of Riverside, 95 Cal.App.4th 761 (2002) (appellate standard of review; burden on party asserting error)
McComber v. Wells, 72 Cal.App.4th 512 (1999) (self-represented litigants held to same standards as attorneys)
Kobayashi v. Superior Court, 175 Cal.App.4th 536 (2009) (propria persona litigants treated equally; no special treatment)
Beardslee v. Superior Court, 53 Cal.3d 68 (1991) (settlement of the record; trial court's discretion to accept/reject statements)
Hardy v. Beardslee, 2 Cal.4th 86 (1992) (settled statement reflection of actual proceedings; reliance on court’s discretion)
Marks v. Superior Court, 27 Cal.4th 176 (2002) (settled statement must reflect testimony and evidence; role of court’s accuracy)
Harris v. Stampolis, 248 Cal.App.4th 484 (2016) (presumed knowledge of law by trial court; coercive issues analyzed under coercive control doctrine)