Moreno v. Naranjo, 465 Mass. 1001

Moreno and Naranjo had an intimate relationship for years and share a minor child.
A prior G. L. c. 209A order existed during a past abuse incident; that order expired.
After another alleged assault and Naranjo moving out of state, Moreno sought a new 209A order.
Ex parte order issued restricting contact and granting Moreno custody of the child.
At a hearing, Moreno requested a one-year extension; the judge extended only six months.
The district court based part of its six-month duration on concerns about Naranjo’s visitation rights, rather than protection from abuse.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether six-month extension was an abuse of discretion	Moreno argues the court erred by considering visitation.	Naranjo argues discretion to extend within statutory limits allows six months.	Yes, improper reliance on visitation; discretion misapplied

Iamele v. Asselin, 444 Mass. 734 (Mass. 2005) (extension must protect from abuse, not affect custody)
Turner v. Lewis, 434 Mass. 331 (Mass. 2001) (209A protects victims; public policy against domestic violence)
Commonwealth v. Gordon, 407 Mass. 340 (Mass. 1990) (statutory mechanism to aid victims of family violence)
Champagne v. Champagne, 429 Mass. 324 (Mass. 1999) (policy against domestic abuse; preservation of protective rights)