Chronister v. Brenneman
Superior Court of Pennsylvania
742 A.2d 190 (Pa. Super. Ct. 1999)
Brenneman (defendant) hit his sixteen-year-old daughter with a belt five or six times after she admitted lying, causing her pain and tears but no lasting marks; later that evening, he retrieved a gun from a downstairs cupboard and made eye contact with her while carrying it upstairs during a discussion about house rules, without any verbal threat. His stepdaughter Chronister (plaintiff) filed a Protection From Abuse petition on the daughter's behalf, and the trial court granted a PFA order, which Brenneman appealed.
Whether a parent's use of corporal punishment causing only temporary pain, without lasting physical injury, constitutes abuse warranting a Protection From Abuse order under Pennsylvania law.