JONATHAN HART
v.
TAYLOR MOORE O/B/O JONATHAN HART, CATHERINE HART, AND KYLIE HART
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A domestic violence injunction against minors must be dissolved when the respondent demonstrates a material change in circumstances through completion of court-ordered programs and voluntary therapy, and the petitioner fails to present evidence of an objectively reasonable fear of future domestic violence.
[1] A domestic violence injunction may be dissolved upon a showing of material change in circumstances, including completion of court-ordered programs and engagement in volun…
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Join FLexlaw to unlock all legal intelligence“Moore—as the minors' representative—did not present any evidence of an objectively reasonable fear of future domestic violence.”
Court's analysis of whether the petitioner met her burden to maintain the injunction
Jonathan Hart sought to dissolve a domestic violence injunction entered against him on behalf of his three children. Hart had completed court-ordered …
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DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
FOURTH DISTRICT
JONATHAN HART, Appellant,
v.
TAYLOR M. MOORE o/b/o Jonathan Hart, Catherine Hart, and Kylie Hart, Appellee.
No. 4D2024-3222
[September 8, 2025]
Appeal from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Elaine Carbuccia, Judge; L.T. Case No. DVCE21- 006587.
Jonathan Hart, Wellington, pro se.
No appearance for appellee.
PER CURIAM.
Jonathan Hart appeals the circuit court’s denial of his motion for reconsideration following the court’s refusal to dissolve a domestic violence injunction entered for his three children. We reverse for two reasons.
First, Hart provided evidence of a change in circumstances. Not only did Hart complete court-ordered classes, but he entered voluntary therapy in March 2022. His therapist testified that Hart had not shown any aggressive behaviors. Second, Moore—as the minors’ representative—did not present any evidence of an objectively reasonable fear of future domestic violence. The son testified to vague threats against Moore, his mother. However, Moore undermined any suggestions that she was fearful of Hart when she informed the court that she told her children they could reach out to Hart when they wanted. See, e.g., Labrake v. Labrake, 335 So. 3d 214, 217-18 (Fla. 1st DCA 2022). Accordingly, we reverse and remand with instructions to dissolve the injunction.
Reversed and remanded.
2
KUNTZ, C.J., GROSS and ARTAU, JJ., concur.
* * *
Not final until disposition of timely filed motion for rehearing.