Painter v. Painter

Summary

The Supreme Court of Delaware affirmed the Family Court's two-year protection-from-abuse order against Father, its temporary custody and visitation provisions, and its related rulings. The Court held that the Family Court's findings that Father's repeated and accusatory text messages constituted domestic violence were not clearly erroneous, and that the court properly assessed credibility and limited the hearing to the recent conduct underlying the petitions. The Court also rejected Father's challenges to the temporary custody and visitation orders and his claim that repeated rulings by the same judicial officers demonstrated bias.