Cavanaugh v. Cavanaugh
Supreme Court of Rhode Island
138 A.3d 707 (R.I. 2016)
After divorcing, Brian Cavanaugh (defendant) frequently yelled and swore at his ex-wife Rosanna (plaintiff) in a threatening manner, and after a court denied her petition to modify his visitation rights, he called her repeatedly, vulgarly gloating about the outcome; Rosanna testified this conduct placed her in fear of bodily harm, and Brian admitted to the described conduct. A magistrate issued a civil restraining order limiting Brian's contact with Rosanna except during child visitation exchanges, the family court affirmed, and Brian appealed.
Whether a finding of domestic abuse sufficient to support a civil protection order requires proof of actual physical harm or an explicit threat of physical harm.