Monthly Archives October 2026

Allen v. Whitehead | D.C. Court of Appeals Expands “Family Member” Under the Intrafamily Offenses Act

In Allen v. Whitehead, No. 25-FM-0607 (D.C. Sept. 3, 2026), the District of Columbia Court of Appeals reversed the Superior Court’s dismissal of a civil protection order petition, holding that a paternal grandmother vested with sole legal custody of her grandchildren qualifies as a “family member” of the children’s biological mother under the Intrafamily Offenses Act, D.C. Code § 16-1001 et seq. Factual Background Fonda Allen, the paternal grandmother, was awarded permanent sole legal and physical custody of her two grandchildren in a prior custody proceeding. Tamieka Whitehead, the children’s biological mother, retained monthly supervised visitation. Allen thereafter petitioned for
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