## Facts

- A 14-year-old (Crump) and a 17-year-old (Blanchette) were in a dating relationship that ended.
- Crump’s mother petitioned for a domestic violence protection order (DVPO) against Blanchette under Washington’s Domestic Violence Prevention Act (chapter 26.50 RCW).
- The petition alleged physical and sexual assaults during the dating relationship.
- At the protection-order hearing, Blanchette appeared without counsel and did not testify due to a pending criminal investigation.
- The trial court found domestic violence and entered a DVPO that included restrictions affecting school attendance.
- Blanchette later sought modification or termination based on new witness declarations; the court modified the school restriction but declined to consider termination, indicating termination should be pursued on appeal.
- Blanchette appealed, arguing the court lacked statutory authority to issue the DVPO and erred by refusing to consider termination.

## Issues

1. Whether chapter 26.50 RCW authorizes a DVPO when the protected person is 14 and therefore does not meet the statutory definition of a qualifying “family or household member” in a dating relationship.
2. Whether the trial court erred by declining to consider termination of the DVPO based on new evidence after modifying the order.

## Decision

- The Court of Appeals reversed the DVPO.
- It held the trial court lacked authority under chapter 26.50 RCW because the alleged victim, as a 14-year-old dating partner, did not fit the statute’s definition of “family or household member.”
- Given the lack of statutory authority to issue the order in the first instance, the termination-related issue was effectively mooted.

## Legal Principles

- Statutory authority to issue a DVPO under chapter 26.50 RCW depends on whether the parties fall within the statute’s defined categories.
- Under RCW 26.50.010(2), a “dating relationship” qualifies only where the persons are “sixteen years of age or older”; a person under 16 cannot qualify as a “family or household member” on the basis of a dating relationship alone.
- RCW 26.50.020(1) allows an adult to petition on behalf of a minor who is a qualifying “family or household member,” but it does not expand the substantive definition of who qualifies.
- Courts must apply the statute’s plain language and definitions as written, even when the alleged conduct is serious.

## Conclusion

The appellate court reversed the domestic violence protection order because the Domestic Violence Prevention Act limits dating-relationship coverage to persons at least sixteen years old, and a parent’s ability to petition on a minor’s behalf does not enlarge that statutory limitation.


Neilson ex rel. Crump v. Blanchette, 201 P.3d 1089 (Wash. Ct. App. 2009)