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Domestic Relations-Order of Protection-Substantial Emotional Distress

Staff Report//July 1, 2026//

Domestic Relations-Order of Protection-Substantial Emotional Distress

Staff Report//July 1, 2026//

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Respondent appealed the order of the trial court granting an order of protection in favor of petitioner. The parties had a tumultuous year-long relationship. The trial court found that both parties had engaged in toxic behavior during their relationship but concluded that respondent had harassed petitioner.

Where the trial court had found no evidence of abuse or stalking, respondent’s “annoying and boorish” calls were insufficient to cause petitioner substantial emotional distress.

Judgment is reversed.

M.N.B. v. A.J.R. (MLW No. 85032/Case No. ED113699 – 5 pages) (Missouri Court of Appeals, Eastern District, Page, J.) Appealed from circuit court, Jefferson County, Argana, J. (Joseph C. McWard for appellant) (Daniel E. Diemer for respondent)

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