Georgia Woods v. Gregory Owens

Summary

The Washington Court of Appeals, Division Two, affirmed the denial of Gregory Owens’s motion to terminate a permanent domestic violence protection order protecting Georgia Woods. The court held that RCW 7.105.500 does not require a mathematical balancing of unweighted factors and concluded that Owens failed to prove a substantial change in circumstances warranting termination. An order dated March 24, 2026, granted motions to publish the previously unpublished opinion filed November 12, 2025.

Holdings

1. The unweighted factors in RCW 7.105.500(4) do not create a mathematical checklist or require the superior court to count factors for and against termination. The superior court has discretion to determine which factors are relevant and how much significance to assign to the evidence concerning each factor.
2. The superior court did not abuse its discretion by finding that Owens failed to prove a substantial change in circumstances warranting termination of the permanent domestic violence protection order.

Questions Presented

1. Whether RCW 7.105.500(4)'s unweighted factors require a mathematical or checklist-based comparison to determine whether a respondent has shown a substantial change in circumstances warranting termination of a protection order.
2. Whether the superior court abused its discretion by finding that Owens failed to prove by a preponderance of the evidence a substantial change in circumstances such that he would not resume, engage in, or attempt to engage in acts of domestic violence if the order were terminated.

Disposition

affirmed