Valerie G. v. Louis G.

—As part of marital dissolution proceedings, appellant Valerie G. sought a domestic violence restraining order (DVRO) against her husband, respondent Louis G., alleging he physically injured her during confrontations between them. On appeal, Valerie contends the court erred in concluding that, because her injuries were suffered during and as a result of physical confrontations she instigated, they did not constitute “ ‘abuse’ ” within the meaning of Family Code 1 section 6203, part of the Domestic Violence Prevention Act (§ 6200 et seq.).

*776 Although section 6203 defines abuse to include an intentionally or recklessly caused bodily injury to the complainant, a finding of abuse is not mandated merely because the complainant shows he or she suffered an injury caused by the other party. Instead, fundamental and well-established principles allow a victim of physical aggression to employ reasonable force to defend his or her person or property against the aggressor, even when such reasonable force causes some bodily injury to the aggressor. The trial court properly recognized that a person who responds reasonably to an aggressor in this way does not commit abuse within the…