Protective orders can play a critical role in protecting individuals from harassment, stalking, and threats of violence. A recent decision from the Missouri Court of Appeals highlights how courts evaluate requests to renew protective orders—and under what circumstances those orders may be extended for a respondent's lifetime.

In L.J.F. v. J.F.G. (Mo. App. W.D., March 10, 2026), the appellate court affirmed a trial court's decision renewing a full order of protection against a former partner and extending it for the remainder of the respondent's life.

This case provides important guidance for individuals seeking protection under Missouri's Adult Abuse Act.

Background of the Case

The parties were formerly in a relationship and share a child together. In 2022, the mother filed a petition for an order of protection alleging harassment and threatening behavior by the father. The petition described repeated unwanted communication, including daily text messages and alleged stalking behavior through online platforms.

A court initially entered an ex parte order of protection, followed by a full order of protection lasting one year. The order prohibited the father from contacting the mother except for communication related to their child and required that such communication occur only through specific channels.

As the order approached expiration, the mother asked the court to renew it. After additional hearings, the trial court renewed the order multiple times. In April 2025, the court issued another renewal and found that the father posed a serious danger to the physical or mental health of the mother. Based on that finding, the court ordered that the protective order remain in effect for the father's lifetime.

The father appealed that decision.

When Can a Missouri Court Renew an Order of Protection?

Missouri law allows courts to renew full orders of protection under the Adult Abuse Act.

To obtain a renewal, the petitioner must generally show—by a preponderance of the evidence—that the conduct supporting the original order occurred and that continued protection is appropriate. Courts look at whether the evidence demonstrates ongoing threats, harassment, stalking, or other conduct that qualifies as domestic violence under Missouri law.

Importantly, renewal of an order of protection can be based on the same type of conduct that justified the original order, including stalking or harassment. The law is designed not only to address past conduct but also to prevent future harm.

Evidence Supporting Renewal of the Protective Order

The trial court heard testimony and reviewed evidence regarding the father's behavior. According to the record, the evidence included:

• Numerous harassing and volatile messages sent by the father to the mother

• Testimony that the communications were threatening and caused the mother to fear for her safety

• Evidence that the father had been arrested for violating the existing order of protection multiple times

• Incidents at their child's sporting events where the father behaved aggressively toward the mother

• An incident in which the father allegedly revved his vehicle and backed rapidly toward the mother's car, causing her to fear for her safety and that of her child

Under Missouri law, stalking involves a course of unwanted conduct that causes alarm or fear of physical harm. The appellate court concluded that the evidence demonstrated a pattern of threatening behavior sufficient to support renewal of the protective order.

Why the Court Allowed a Lifetime Protective Order

Missouri law allows a court to renew an order of protectionfor the respondent's lifetime if the court makes written findings that the respondent poses a serious danger to the physical or mental health of the petitioner or a member of the petitioner's household.

In this case, the trial court made that finding.

On appeal, the father argued that the court did not make sufficiently detailed findings to justify a lifetime order. However, the appellate court rejected this argument because the father failed to properly preserve the issue for appeal. Specifically, he did not raise the alleged deficiency in a motion asking the trial court to amend the judgment.

Because the issue was not properly preserved, the appellate court declined to review it and affirmed the lifetime order of protection.

What This Case Means for Victims of Harassment or Stalking

This decision highlights several important points for individuals seeking protection under Missouri law:

• Protective orders can be renewed when evidence shows ongoing harassment, stalking, or domestic violence.

• Courts will consider patterns of conduct, not just isolated incidents.

• Violating an existing protective order can significantly strengthen the case for renewal.

• In serious situations, courts may issue lifetime orders of protection to ensure long-term safety.

The decision also illustrates that appellate courts generally defer to the trial court's assessment of witness credibility and factual evidence in protective order cases.

Getting Legal Help With Orders of Protection in Missouri

Protective order proceedings can have serious and lasting consequences. For victims, they can provide critical protection from harassment or threats. For individuals accused of misconduct, they can affect housing, employment, firearms rights, and child custody arrangements.

An experienced attorney can help you:

• File a petition for an order of protection

• Defend against allegations of abuse, stalking, or harassment

• Prepare evidence and witness testimony for court

• Handle renewals or appeals of protective orders

If you have questions about obtaining or responding to an order of protection in Missouri, consulting with a knowledgeable attorney can help you understand your rights and the legal options available to you.