14.0 What Has Met the Test of "Abuse"

Commonwealth v. Gordon, 407 Mass. 340, 349-350 (1990)

Defendant appeared at victim's house in violation of 209A order, called victim "bitch" and "whore," and prevented victim from closing door to her house by propping his back against it.

Commonwealth v. Robicheau, 421 Mass. 176 (1995)

Defendant parked and stood in the street in front of victim's house in violation of 209A order, yelled obscenities and made an obscene gesture, and later told her over the telephone that he would kill her.

Wooldridge v. Hickey, 45 Mass. App. Ct. 637 (1998)

Appeals Court assumes there is sufficient evidence to support the issuance of the c. 209A order where appellant failed to provide a full transcript and where the Judge asked plaintiff if she felt subject to some danger of imminent physical harm, to which she responded with "Yes." And, where, when asked, "Why? Why do you feel that?" the answer was "Because, ‘inaudible.’ " This despite Appeals Court’s concern that plaintiff sought and judge granted order to help plaintiff level the playing field in a complaint for modification of divorce judgment.

Litchfield v. Litchfield, 55 Mass. App. Ct. 354 (2002)

Order to keep 500 yards away from plaintiff and one mile from her home deemed proper, given defendant’s 10-year history of beating and threatening plaintiff and his prior criminal