This question has been addressed in 1 Texas court opinion:
COA05 — February 11, 2026
In Sattar v. Hazlitt, the Dallas Court of Appeals reviewed a trial court's denial of Anum Sattar's application for a protective order against Ryan Hazlitt. The case arose from "dueling" protective order filings, with Sattar claiming a history of emotional abuse and a specific instance involving a firearm. The trial court excluded testimony regarding Hazlitt's emotional slights and manipulative behavior, focusing strictly on whether the conduct met the definition of "family violence" under Texas Family Code § 71.004. The appellate court affirmed the denial, holding that the trial court did not abuse its discretion in finding Sattar's testimony about physical threats lacked credibility and that general interpersonal misconduct is insufficient to warrant a Title 4 protective order.
Litigation Takeaway
“To secure a protective order, an applicant must provide credible evidence of physical harm or imminent threats; general "bad behavior," infidelity, or emotional manipulation does not meet the statutory definition of family violence in Texas.”