Revised Code of Washington

Wash. Rev. Code § 7.105.225 (2026)

Grant of order, denial of order, and improper grounds

✓ current as of May 2026

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(1) The court shall issue a protection order if it finds by a preponderance of the evidence that the petitioner has proved the required criteria specified in (a) through (f) of this subsection for obtaining a protection order under this chapter.

(a) For a domestic violence protection order, that the petitioner has been subjected to domestic violence by the respondent.

(b) For a sexual assault protection order, that the petitioner has been subjected to nonconsensual sexual conduct, nonconsensual sexual penetration, or commercial sexual exploitation by the respondent.

(d) For a vulnerable adult protection order, that the petitioner has been abandoned, abused, financially exploited, or neglected, or is threatened with abandonment, abuse, financial exploitation, or neglect by the respondent.

(e) For an extreme risk protection order, that the respondent poses a significant danger of causing personal injury to self or others by having in the respondent's custody or control, purchasing, possessing, accessing, receiving, or attempting to purchase or receive, a firearm.

(f) For an antiharassment protection order, that the petitioner has been subjected to unlawful harassment by the respondent.

(2) The court may not deny or dismiss a petition for a protection order on the grounds that:

(a) The petitioner or the respondent is a minor, unless provisions in this chapter specifically limit relief or remedies based upon a party's age;

(b) The petitioner did not report the conduct giving rise to the petition to law enforcement;

(c) A no-contact order or a restraining order that restrains the respondent's contact with the petitioner has been issued in a criminal proceeding or in a domestic relations proceeding;

(d) The relief sought by the petitioner may be available in a different action or proceeding, or criminal charges are pending against the respondent;

(e) The conduct at issue did not occur recently or because of the passage of time since the last incident of conduct giving rise to the petition; or

(f) The respondent no longer lives near the petitioner.

(3) In proceedings where the petitioner alleges that the respondent engaged in nonconsensual sexual conduct, nonconsensual sexual penetration, or commercial sexual exploitation, the court shall not require proof of physical injury on the person of the petitioner or any other forensic evidence. Denial of a remedy to the petitioner may not be based, in whole or in part, on evidence that:

(a) The respondent was voluntarily intoxicated;

(b) The petitioner was voluntarily intoxicated; or

(4) In proceedings where the petitioner alleges that the respondent engaged in stalking, the court may not require proof of the respondent's intentions regarding the acts alleged by the petitioner.

(5) In proceedings where the petitioner alleges that the respondent engaged in commercial sexual exploitation, denial of a remedy to the petitioner may not be based, in whole or in part, on evidence that the petitioner consented to sexual conduct or sexual penetration.

(6) If the court declines to issue a protection order, the court shall state in writing the particular reasons for the court's denial. If the court declines a request to include one or more of the petitioner's family or household member who is a minor or a vulnerable adult in the order, the court shall state the reasons for that denial in writing. The court shall also explain from the bench:

(a) That the petitioner may refile a petition for a protection order at any time if the petitioner has new evidence to present that would support the issuance of a protection order;

(b) The parties' rights to seek revision, reconsideration, or appeal of the order; and

(7) A court's ruling on a protection order must be filed by the court in writing and must be made by the court on the mandatory form developed by the administrative office of the courts.

[ 2024 c 298 s 12; 2021 c 215 s 29.]

Notes:

Effective date—2024 c 298: See note following RCW 9A.40.100.

Effective date—2022 c 268; 2021 c 215: See note following RCW 7.105.900.

Notes of Decisions

Cited in 60 cases (60 in the last 5 years), 2023–2026 · leading case: Allison N. Crowston, V. Ryan R. Cory (Wash. Ct. App. 2025).

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Allison N. Crowston, V. Ryan R. Cory (Wash. Ct. App. 2025). · cites it 19× “1 A new version of RCW 7.105.225 is set to be effective as of July 1, 2025, but the relevant language of the statute will remain the same.”

Dyllan Tyme Thomson, V. Trent Weseman (Wash. Ct. App. 2026). · cites it 12× “The parenting plan between Thomson and Ekholm requires weekly custody exchanges at the parents’ residences although the parents had been meeting at a local store for the exchanges for several years.”

In the Matter of the Dom. Violence Prot. Order for: Rejoice Gadza Neal (Wash. Ct. App. 2026). · cites it 12× “And in that particular situation, it tells the Court things it can’t consider, and that one of them in [RCW 7.105.225](2)(b) is that the petitioner did not report the conduct giving rise to the petition to law enforcement.”

Signe Bergman, V. Ivan Moto (Wash. Ct. App. 2024). · cites it 9× “1 On remand, the trial court may 1 Because we accept the concession that the court legally erred in interpreting RCW 7.105.225, it is unnecessary to address any other issues the Appellant raises.”

In the Matter of the Dom. Violence Prot. Order for H.P. (Wash. Ct. App. 2024). · cites it 6× “RCW 7.105.225, the applicable statute in the Benton County DVPO proceeding, states in relevant part: (1) The court shall issue a protection order if it finds by a preponderance of the evidence that the petitioner has proved the required criteria specified in (a) through (f) of…”

Chelsi A. Eastwood Cooley, V. Donald Michael Hall (Wash. Ct. App. 2025). · cites it 6× “Under RCW 7.105.225(1), “[t]he court shall issue a protection order if it finds by a preponderance of the evidence that the petitioner has proved the required criteria.”

Hope Gullien & Jessica Norris v. Thomas Lee Sauers (Wash. Ct. App. 2024). · cites it 5× “The trial court reasoned that under RCW 7.105.225, the conduct described in the petition met the definition of nonconsensual sexual conduct and it listed the reasons a petition could not be denied or dismissed.”

Amanda Lynn Wilhelm, V. Trevor Scott Altman (Wash. Ct. App. 2024). · cites it 4× “” For sexual assault protection orders, the statute requires “that the petitioner has been subjected to nonconsensual sexual conduct or nonconsensual sexual penetration by the respondent.”

Gillian Timaeus, V Chris Timaeus (Wash. Ct. App. 2025). · cites it 4× “RCW 7.105.225 directs courts to grant protection orders if they find, by a preponderance of the evidence, that “the petitioner has been subjected to domestic violence by the respondent.”

Nanee Vinod Bandrapalli, V. Jill Bandrapalli (Wash. Ct. App. 2026). · cites it 4× “The trial court expressly applied the applicable standard under RCW 7.105.225 and declined to issue a DVPO because the father failed to prove, by a preponderance of the evidence, that he was subjected to domestic violence by the mother.”

Jasmine M. Acosta v. Bryon K. McQuaid (Wash. Ct. App. 2023). · cites it 3× “But an applicable statute precluded such deference, stating a DVPO “shall not be denied or delayed on the grounds that the relief is available in another action.”

In the Matter of the Vulnerable Adult Petition for: Sylvia Karen Humrich (Wash. Ct. App. 2024). · cites it 3× “3d 1068 (2014), or dismissed the VAPO petition altogether pursuant to RCW 7.105.225. 4 No. 39337-2-III Vulnerable Adult Protection Order for Humrich We reject Phillip’s position because Sylvia did not object to entry of the VAPO.”

Show all 60 citing cases →

— Wash. Rev. Code § 7.105.225(1) — 9 cases

Amanda Lynn Wilhelm, V. Trevor Scott Altman (Wash. Ct. App. 2024). “” For sexual assault protection orders, the statute requires “that the petitioner has been subjected to nonconsensual sexual conduct or nonconsensual sexual penetration by the respondent.”

Ashley Allen v. Frank Joseph Allen (Wash. Ct. App. 2024).

Signe Bergman, V. Ivan Moto (Wash. Ct. App. 2024). “1 On remand, the trial court may 1 Because we accept the concession that the court legally erred in interpreting RCW 7.105.225, it is unnecessary to address any other issues the Appellant raises.”

In the Matter of the Vulnerable Adult Petition for: Sylvia Karen Humrich (Wash. Ct. App. 2024). “3d 1068 (2014), or dismissed the VAPO petition altogether pursuant to RCW 7.105.225. 4 No. 39337-2-III Vulnerable Adult Protection Order for Humrich We reject Phillip’s position because Sylvia did not object to entry of the VAPO.”

Amorea Rocha, V. Hamal Strand (Wash. Ct. App. 2024).

— Wash. Rev. Code § 7.105.225(1)(a) — 25 cases

Allison N. Crowston, V. Ryan R. Cory (Wash. Ct. App. 2025). “1 A new version of RCW 7.105.225 is set to be effective as of July 1, 2025, but the relevant language of the statute will remain the same.”

In the Matter of the Dom. Violence Prot. Order for: Rejoice Gadza Neal (Wash. Ct. App. 2026). “And in that particular situation, it tells the Court things it can’t consider, and that one of them in [RCW 7.105.225](2)(b) is that the petitioner did not report the conduct giving rise to the petition to law enforcement.”

Katie Dale, V. Donald Cain Iii (Wash. Ct. App. 2024).

Jake Platt, V. Paige Wager (Wash. Ct. App. 2024).

— Wash. Rev. Code § 7.105.225(1)(b) — 6 cases

Shantel Schrag v. Matthew Schrag (Wash. Ct. App. 2024).

Ashley Allen v. Frank Joseph Allen (Wash. Ct. App. 2024).

In the Matter of the Sexual Assault Prot. Order for: Amanda Lee Lorenzen (Wash. Ct. App. 2024).

Hope Gullien & Jessica Norris v. Thomas Lee Sauers (Wash. Ct. App. 2024). “The trial court reasoned that under RCW 7.105.225, the conduct described in the petition met the definition of nonconsensual sexual conduct and it listed the reasons a petition could not be denied or dismissed.”

— Wash. Rev. Code § 7.105.225(1)(c) — 1 case

Alexandria Avona, V. Tamru Terfa (Wash. Ct. App. 2025).

— Wash. Rev. Code § 7.105.225(1)(d) — 2 cases

In the Matter of the Vulnerable Adult Petition for: Marion Cox (Wash. Ct. App. 2024).

— Wash. Rev. Code § 7.105.225(1)(f) — 16 cases

Christian Doscher, V. Richard Lawrence & Fred Johns (Wash. Ct. App. 2025).

Joshua Mckinney, V. Christine Booker (Wash. Ct. App. 2024).

Dimitar K. Dermendziev, V. Georghe Sandru (Wash. Ct. App. 2024).

Amorea Rocha, V. Hamal Strand (Wash. Ct. App. 2024).

Loanita Adams, V. Nasro Ugas (Wash. Ct. App. 2025).

— Wash. Rev. Code § 7.105.225(2) — 5 cases

In the Matter of the Dom. Violence Prot. Order for H.P. (Wash. Ct. App. 2024). “RCW 7.105.225, the applicable statute in the Benton County DVPO proceeding, states in relevant part: (1) The court shall issue a protection order if it finds by a preponderance of the evidence that the petitioner has proved the required criteria specified in (a) through (f) of…”

Elizabet Starling, V. Austin Gregory Smogar (Wash. Ct. App. 2026).

— Wash. Rev. Code § 7.105.225(2)(a) — 2 cases

Anne Jones Obo C.j., V. Maguire Darragh (Wash. Ct. App. 2025).

— Wash. Rev. Code § 7.105.225(2)(b) — 1 case

— Wash. Rev. Code § 7.105.225(2)(c) — 1 case

— Wash. Rev. Code § 7.105.225(2)(d) — 4 cases

Chelsi A. Eastwood Cooley, V. Donald Michael Hall (Wash. Ct. App. 2025). “Under RCW 7.105.225(1), “[t]he court shall issue a protection order if it finds by a preponderance of the evidence that the petitioner has proved the required criteria.”

Jasmine M. Acosta v. Bryon K. McQuaid (Wash. Ct. App. 2023). “But an applicable statute precluded such deference, stating a DVPO “shall not be denied or delayed on the grounds that the relief is available in another action.”

Nanee Vinod Bandrapalli, V. Jill Bandrapalli (Wash. Ct. App. 2026). “The trial court expressly applied the applicable standard under RCW 7.105.225 and declined to issue a DVPO because the father failed to prove, by a preponderance of the evidence, that he was subjected to domestic violence by the mother.”

— Wash. Rev. Code § 7.105.225(2)(e) — 8 cases

Amanda Helen Taylor v. Todd Emory Taylor (Wash. Ct. App. 2024).

Aiden Asbach v. Adam Couto (Wash. Ct. App. 2026).

— Wash. Rev. Code § 7.105.225(3) — 1 case

— Wash. Rev. Code § 7.105.225(5) — 6 cases

Gillian Timaeus, V Chris Timaeus (Wash. Ct. App. 2025). “RCW 7.105.225 directs courts to grant protection orders if they find, by a preponderance of the evidence, that “the petitioner has been subjected to domestic violence by the respondent.”

Matthew William Ezell, V. Audrey Leigh Cavins-ezell (Wash. Ct. App. 2026).

Jake Platt, V. Paige Wager (Wash. Ct. App. 2024).

— Wash. Rev. Code § 7.105.225(6) — 3 cases

Dyllan Tyme Thomson, V. Trent Weseman (Wash. Ct. App. 2026). “The parenting plan between Thomson and Ekholm requires weekly custody exchanges at the parents’ residences although the parents had been meeting at a local store for the exchanges for several years.”

Stacey Sheridan, V. James Sheridan (Wash. Ct. App. 2026).

Meghan D. Grolley, Respondent/cross-appellant V Autumn Livermore, Appellant/cross-respondent (Wash. Ct. App. 2026).

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