In re E.M. CA2/7

DISCUSSION

The juvenile court has authority to restrain any person from contacting a dependent child and any parent of that child. (§ 213.5, subd. (a) & (d)(1).) Restraining orders may be based on “reasonable proof of harassment,” defined as “unlawful violence, a credible threat of violence, or a knowing and willful course of conduct directed at a specific person that seriously alarms, annoys, or harasses the person, and that serves no legitimate purpose.” (Code Civ. Proc., §§ 527, 527.6, subds. (b)(3), (b)(7) & (d); § 213.5, subd. (a).) Restraining orders based on domestic violence may be supported by “reasonable proof of a past act or acts of abuse.” (Fam. Code, § 6300, subd. (a); § 213.5, subd. (a).) While evidence of past physical harm may be sufficient to justify the issuance of a juvenile court restraining order, the issuance of the order “does not require such evidence[;] [n]or does it require evidence of a reasonable apprehension of future physical abuse.” (In re Bruno M. (2018) 28 Cal.App.5th 990, 997 (Bruno M.), citations and italics omitted.) Evidence that a person “‘disturbed the peace’” of the child or the other parent can suffice. (Ibid.) The ultimate question is…