Domestic violence has long been recognized as a pressing law enforcement and societal concern, and both federal and state governments have continued to pursue strategies to address the issue. Beyond the criminal threatening, assaults, batteries, and other physical atrocities that victims face, domestic violence provides an added horror—“obliterating personhood, suspending identity and nullifying any notion of personal autonomy.” To address these concerns, legislatures created Protection from Abuse Orders (hereinafter PFAs), to protect those that have been subject to abuse from trusted family members or dating partners. Unfortunately, victims then place their trust in the system, which often fails to deter future violence and provides minimal consequences for those who violate a PFA.

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