In the matters of E.K. v. J.R.A. and J.R.A. v. E.K., 2020 EDA 184, the Superior Court of Pennsylvania reviewed two interrelated orders entered by the trial court regarding a mother (E.K.) and father (J.R.A.) litigating a protection from abuse (PFA) and custody issues, both of which were appealed by the father. At issue was whether alleged past acts of violence could be introduced as evidence at a PFA hearing and whether notice is required before entering a custody contempt order.

The mother and father have a substantial history of custody and PFA litigation against one another. Over the course of their litigation, the mother has alleged many incidences of abuse and threatening behavior committed by the father, such as inundating her with hundreds of text messages, slamming her head on the ground, and injuring her wrist by driving a truck while her hand was stuck in the steering wheel. In the parallel custody action between the parties, The mother made similar allegations as those in her PFA. The parties resolved both the PFA and the custody matter through negotiated agreements.