Melanie Gamble v. William Gamble

Domestic Violence: Final protective order: Clear and convincing evidence:

CSA No. 1193, Sept. Term 2013. Unreported.

Opinion by Kehoe, J. Filed: April 22, 2014.

Appeal from Prince George’s County. Affirmed in part, vacated in part.

RecordFax #14-0422-00, 12 pages.

The circuit court erred in ruling on ancillary relief requested as part of a final protective order without permitting the petitioner to fully present evidence regarding her need for the requested relief, and also in applying the “clear and convincing” evidence standard (which, at the time, applied to the determination of whether abuse occurred) to determine whether petitioner had shown a need for the requested relief.

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