## In re Marriage of Brubaker & Strum (2022) 73 Cal. App. 5th 525 2nd District, Division 7 Filed January 3, 2022 ### Procedural History **Trial Court:** * Denied Betsey’s request to renew a restraining order * Granted Andy's motion in limine. * Andy successfully excluded Betsey's evidence regarding abuse and restraining order violations that occurred before the dissolution of marriage trial. **Appellate Court:** * REVERSED: * The improperly excluded evidence is relevant to whether Betsey had a reasonable fear of future abuse. * Cannot exclude such evidence as a matter of law. ### Further Reading: * [[Cal. Fam. Code § 6345]] * [[Case Law/R/Ritchie v. Konrad (2004) 115 Cal.App.4th 1275]] * [[Case Law/A/Ashby v. Ashby (2021) 68 Cal.App.5th 491]] <!-- citation-library:start --> ## Citation reference Brubaker & Strum, In re Marriage of (2021) 73 Cal.App.5th 525, 288 Cal.Rptr.3d 256 > [!info] Working notes > This is a personal working note. Citation details are for reference; opinion and current-status verification may still be pending. <!-- citation-library:end -->