Background

• Sarah Craig filed for a protection from abuse order alleging Krystal Caron (the ex‑wife of Craig’s boyfriend) entered Craig’s home uninvited, refused to leave when asked, and struck Craig; Craig’s three‑year‑old son witnessed the incident.
• Caron moved to dismiss for lack of standing, arguing Craig was not a “family or household member or dating partner” under 19‑A M.R.S. § 4002.
• The district court denied dismissal, held an evidentiary hearing, found Caron entered without permission, refused to leave, and struck Craig, and concluded those acts constituted stalking under 17‑A M.R.S. § 210‑A, issuing a protection from abuse order.
• Caron appealed, arguing the parties were not within the statutory family/household/dating categories and that the conduct did not meet the statutory definition of stalking (which requires a “course of conduct” of two or more acts).
• The Supreme Judicial Court examined whether the single episode (entry, refusal to leave, assault) constituted the statutorily required “two or more acts” of stalking and considered legislative history showing stalking was intended to reach repeated or separated acts.
• The Court concluded the facts did not satisfy the stalking definition and vacated the protection from abuse judgment, noting Craig could seek relief under the protection from harassment statute for a single incident.

Issues

Key Cases Cited

• Preston v. Tracy, 942 A.2d 718 (Me. 2008) (standard for trial court findings based on competent evidence)
• L’Heureux v. Michaud, 938 A.2d 801 (Me. 2007) (statutory interpretation starts with plain language; ambiguity warrants legislative history review)