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Abstract: 

Our regular review of appellate court rulings examines six important decisions addressing stalking, social media abuse, and orders of protection. In People v. Planchard, People v. Planchard (California Court of Appeal), the court held that indirect social media threats can satisfy stalking statutes; conviction affirmed, emphasizing foreseeability and digital evidence preservation. In State v. Petersen, State v. Petersen (Wisconsin Court of Appeals), a “no social media” supervision condition was upheld as reasonably related to rehabilitation and victim protection. In State v. Lemieux, State v. Lemieux (Maine Supreme Judicial Court), the court ruled that constitutional challenges to underlying convictions cannot be raised in probation revocation proceedings; post-conviction review is required. In Matter of Samah DD. v. Mark VV., Matter of Samah DD. v. Mark VV. (New York Appellate Division), extensive social media harassment justified a five-year protective order, recognizing evolving digital abuse risks. In N.B. v. L.B., N.B. v. L.B. (Indiana Court of Appeals), repeated threats and harassment supported a two-year order, though highlighting the high burden of proving “credible threat.” Finally, in People v. Horton, People v. Horton (California Court of Appeal), a ten-year order protecting both victim and family was upheld, though overbroad weapons restrictions were narrowed—reinforcing broad victim protection in stalking contexts.

Keywords: Stalking, Social Media Abuse, Orders of Protection

Affiliations:  1: Contributing Editor; 2: Associate Editor.