The legal basis for extending a Civil Protection Order is set forth in D.C. Code § 16-1005(d-1), which authorizes a judicial officer to extend an order upon motion of any party for good cause shown. A finding that the respondent violated the CPO is not required.

Good cause exists where the petitioner demonstrates a cognizable danger that the respondent will commit or threaten to commit a criminal offense against the petitioner in the coming year if the order is not extended. In assessing good cause, the court must consider the entire mosaic of the case, including evidence of what occurred before the original CPO was issued, the nature of the underlying conduct, events since the CPO and any prior extensions, the parties’ current circumstances, and whether the balance of equities favors extension.

A recent Court of Appeals case specifically addressed extension of a CPO order. In McKenzie v. Persaud, 346 A.3d 154 (D.C. 2025), Petronella McKenzie sought a second extension of a Civil Protection Order against her former husband, Paul Persaud. The parties had a history of sexual, physical, and emotional abuse that occurred in Guyana. After relocating to the District of Columbia, McKenzie obtained a consent CPO in February 2020.

That order was later modified due to threats made by Persaud and was extended in 2021 after he committed technical violations of the order.  Those technical violations in 2021 consisted of indirect contact that violated the stay-away and no-contact provisions of the CPO, such as prohibited communications through third parties or other non-direct means of reaching McKenzie.

\McKenzie argued for the second extension based on her continued reasonable fear of Persaud, the contentious ongoing custody litigation between the parties, and recent changes to the child’s visitation schedule that heightened her anxiety. She maintained that the history of serious abuse, combined with these current circumstances, created good cause to extend the protective order.

Persaud opposed the extension, contending that he had committed no violations of the existing CPO since the prior extension and had demonstrated no current danger to McKenzie. He argued that her fear, while acknowledged, was no longer objectively reasonable given the passage of time and absence of recent threatening conduct.

The trial court acknowledged the parties’ history of abuse and McKenzie’s ongoing fear but found that Persaud had committed no further violations or shown current danger since the last extension. It therefore concluded that good cause had not been established and denied the motion for a second extension.

The District of Columbia Court of Appeals affirmed the trial court’s ruling. The Court held that the trial judge applied the correct legal standard, properly considered the entire mosaic of the parties’ relationship, and made sufficient factual findings. It concluded that the trial court did not abuse its discretion in denying the extension.

Refer to our Washington DC Divorce page for more specific resources.