How does the Court of Appeal review a restraining order under the Domestic Violence Act?

The trial court's decision whether to grant relief under the DVPA required it to resolve disputed facts based on credibility determinations. Our review of that decision is for an abuse of discretion. (Burquet v. Brumbaugh (2014) 223 Cal.App.4th 1140, 1143 ["A granting or denial of injunctive relief is generally reviewed by the appellate court based upon the abuse of discretion standard."] (Burquet).) In applying this deferential standard, we review the record to determine whether the trial court's ruling is supported by substantial evidence. (Ibid.) Our review presumes that all factual disputes were resolved in the prevailing party's favor, unless the trial court indicated otherwise. (Ibid. ["'We must accept as true all evidence . . . tending to establish the correctness of the trial court's findings . . . , resolving every conflict in favor of the judgment.'"].) If there is substantial evidence, we must affirm the judgment unless the trial court "exceeded 'the bounds of reason'" or applied the wrong legal standard in exercising its discretion. (Id. at p. 1144.)⁵

2. The DVPA

"The DVPA authorizes issuance of an order restraining a person 'for the purpose of preventing a recurrence of domestic violence and ensuring a period of separation of the persons involved, if an affidavit . . . shows, to the satisfaction of the court, reasonable proof of a past act or acts of abuse.' ([Fam. Code,] 6300.)" (Gonzalez v. Munoz, supra, 156 Cal.App.4th at p. 421.)

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