Wasilchen v. Chapman CA3, C100739

Tarra Wasilchen sought a DVRO against David Chapman, a North Carolina resident, in Yolo County, California.
Chapman allegedly committed domestic violence that Tarra claimed occurred in California during visits to Tarra's family in 2023.
Chapman moved to quash for lack of personal jurisdiction; the trial court granted and dismissed the DVRO.
Tarra appealed, arguing the California incidents established jurisdiction or, alternatively, that the court erred by addressing merits at the jurisdictional stage.
The appellate court held the trial court implicitly found no California domestic violence acts and affirmed dismissal based on substantial evidence.
Key factual disputes about the California incidents were resolved in favor of Chapman, limiting any California nexus.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did California have personal jurisdiction over Chapman based on alleged California acts of DV?	Wasilchen contends two California DV acts created a jurisdictional nexus.	Chapman argues no California acts support jurisdiction; contacts are NC-based.	No, California lacked jurisdiction; the acts were not found to constitute DV in California.
Did the trial court improperly resolve merits at the jurisdiction stage by considering DVMA-type acts?	Merits related to DV were necessary to establish jurisdiction.	Jurisdictional facts may overlap with merits; the court properly evaluated alleged DV acts.	The court did not err; jurisdictional facts overlapped with merits and supported dismissal.
Was the assessment of the two California incidents properly resolved under the substantial evidence standard?	Trial court found two California incidents true as DV acts.	The court credited Chapman’s testimony and did not find those incidents constitute DV.	Yes; the court’s finding that the incidents were not significant DV acts is supported by substantial evidence.

Hogue v. Hogue, 16 Cal.App.5th 833 (Cal. App. 5th Dist. 2017) (single California DV act can support jurisdiction)
Vons Companies, Inc. v. Seabest Foods, Inc., 14 Cal.4th 434 (Cal. 1996) (minimum contacts and fair play in jurisdiction analysis)
Automobile Antitrust Cases I & II, 135 Cal.App.4th 100 (Cal. App. 2005) (jurisdiction overlaps with merits; evidence may bear on both)
Damron (Doe v. Damron), 70 Cal.App.5th 684 (Cal. App. 2021) (specific vs general jurisdiction; importance of forum contacts)
Lafayette Morehouse, Inc. v. Chronicle Publishing Co., 39 Cal.App.4th 1379 (Cal. App. 1995) (record clarity and appellate review of trial court findings)