Divorce and family disputes can be some of the most emotionally draining experiences in life. If you’re between 30 and 65, living in Dallas or surrounding areas like Irving, Garland, or Richardson, and facing issues like harassment, threats, or violence in a relationship, know that you’re not alone. These situations often escalate, leaving you feeling vulnerable and uncertain about the future. As a dedicated Dallas divorce attorney with over 25 years of experience, I’ve seen how protective orders can provide crucial safety and peace of mind. In this article, we’ll explore a recent Texas case, Garza v. Renteria, which highlights the complexities of family violence and stalking in protective order proceedings. Whether you’re dealing with a contested divorce in Dallas or seeking child custody arrangements, understanding cases like this can empower you to make informed decisions. If you’re ready to discuss your options, consider scheduling a Dallas divorce lawyer consultation today.
Why Protective Orders Matter in Dallas Family Law
Protective orders are legal tools designed to shield individuals from harm, especially in cases involving family violence or dating relationships. In Texas, these orders can restrict contact, prohibit certain behaviors, and even last for extended periods if the court finds sufficient evidence of ongoing threats. For residents in North Dallas, Farmers Branch, or Highland Park, navigating these orders requires a skilled family law attorney serving Dallas who understands local courts and statutes.
Family violence isn’t limited to physical harm—it includes threats, harassment, and stalking that create fear. If you’re in a situation where an ex-partner is making repeated unwanted communications, a protective order might be necessary. As a Dallas divorce attorney, I emphasize honest assessments: we’ll evaluate your case realistically, without inflated promises, to help you decide if court intervention is the right step.
Case Summary: Garza v. Renteria – A Deep Dive into Stalking and Family Violence
As reported in the csae of Garza v. Renteria, decided by the Court of Appeals of Texas in Eastland on August 21, 2025, appellant Michelle Ariana Garza challenged a protective order issued in favor of appellees Patrick Renteria and his wife, Leslie Renteria. This opinion, which has not yet been released for permanent publication, underscores the intersection of family violence, dating violence, stalking, and harassment under Texas law. The trial court granted a 10-year protective order, and the appellate court affirmed it with modifications to include necessary findings. Let’s break down the facts, proceedings, and rulings in detail.
The background stems from a prior dating relationship between Garza and Patrick Renteria. Appellees alleged that Garza committed acts of family violence by threatening them, placing them in reasonable fear of imminent physical harm, bodily injury, assault, or sexual assault. They also claimed Garza engaged in stalking and harassment, and was likely to continue such behavior. The protective order was sought under both the Texas Family Code (Chapters 81–88) and the Code of Criminal Procedure (Chapter 7B).
At the evidentiary hearing on November 27, 2023, in the 280th District Court of Harris County, Texas, testimony revealed a pattern of escalating aggression. Patrick testified that Garza had been abusive and aggressive toward him and his children, making threats including blackmail and extortion. Garza harassed Patrick and his former employer by posting a link to a pornographic website on the company’s Facebook page and sending it to over 100 affiliated businesses, leading to his termination. Even after an ex parte protective order was issued, Garza violated it by continuing to post, harass, call his job, tag family members, and send messages from unknown numbers.
Leslie Renteria, Patrick’s wife and Garza’s third cousin, testified to fearing for her safety and that of her children due to Garza’s erratic and aggressive behavior. She described Garza’s threats as violent and repetitive. Exhibits, including text messages, emails, and Facebook posts, showed Garza subjecting Patrick to public ridicule in a manner intended to harass, annoy, embarrass, abuse, and offend. Patrick’s affidavit detailed threats to harm his family and himself, including statements that Garza would come to his job to cause harm.
Garza countered by claiming the Facebook posts were made by a friend, Rolinda, using a fake profile, and that she had asked her to stop. However, the trial court found this unconvincing.
In its oral rendition at the hearing’s end, the trial court granted the protective order for 10 years, finding that Garza committed family violence under Family Code § 71.004 (threats against family members) and dating violence under § 71.002 (between Garza and Patrick). It also found probable cause to believe Garza committed stalking and harassment under Penal Code §§ 42.072 and 42.07(a)(7), which involves repeated electronic communications likely to harass or offend. The court noted the scheme or course of conduct indicated Garza was likely to continue.
The signed protective order on January 4, 2024, only mentioned dating and family violence, omitting the stalking findings. On appeal, Garza argued the trial court failed to make necessary findings for an order longer than two years under the Family Code (§§ 85.001, 85.025(a-1)(1)), which requires a felony-level act involving family violence (stalking is a felony), and under the Code of Criminal Procedure (art. 7B.003(b), 7B.052), which mandates findings of probable cause for stalking and likelihood of future conduct.
The appellate court reviewed under an abuse of discretion standard, considering legal and factual sufficiency. Viewing evidence in the light most favorable to the findings (In re A.C., 560 S.W.3d 624 (Tex. 2018)), it concluded the oral rendition included the required findings: probable cause for stalking (a felony involving family violence) and likelihood of future engagement. The evidence—repetitive threats, violations of the ex parte order, and escalating harassment—was legally and factually sufficient to support these.
Stalking under Penal Code § 42.072 requires, on more than one occasion pursuant to the same scheme, conduct constituting harassment (§ 42.07) that causes the victim to feel harassed, terrified, etc., and would do so to a reasonable person. Garza’s actions met this: repeated electronic communications causing fear and offense.
The court modified the order to explicitly include:
1. Probable cause exists that Garza committed stalking under § 42.072, a felony involving family violence.
2. The nature of the conduct indicates likelihood of future stalking.
It affirmed as modified, emphasizing that protective orders under the Code of Criminal Procedure can last a lifetime if warranted, while Family Code orders exceed two years only with felony findings.
This case illustrates how Texas courts prioritize victim safety in family violence cases, even when evidence is testimonial and circumstantial. For those in similar situations, consulting a family lawyer in Dallas can clarify if a protective order fits your needs.
Key Takeaways from Garza v. Renteria for Dallas Residents
Cases like Garza v. Renteria offer valuable lessons for anyone navigating family law issues in Dallas, Mesquite, or DeSoto. Here are the key criteria courts consider when issuing protective orders:
1. **Evidence of Family or Dating Violence**: Threats or acts placing someone in fear of imminent harm qualify, as seen in Garza’s repeated communications.
2. **Stalking and Harassment Findings**: Repeated electronic contacts intended to alarm or offend can lead to felony-level charges, extending order durations.
3. **Likelihood of Future Conduct**: Courts assess patterns, like Garza’s violations of interim orders, to predict ongoing risks.
4. **Sufficiency of Evidence**: Testimonial evidence, affidavits, and exhibits suffice if credible; the factfinder judges witness reliability.
5. **Oral vs. Written Renditions**: Oral findings at hearings can support modifications on appeal to ensure the order “speaks the truth.”
These insights highlight why early intervention with a child custody lawyer in Dallas is crucial if children are involved.
How a Dallas Divorce Attorney Can Protect Your Family
At our firm, we specialize in divorce, child custody, child support, asset division, protective orders and mediation. With a compassionate yet strategic approach, we’re committed to being tough in court if necessary—whether handling an uncontested divorce in Dallas or a high-stakes contested divorce in Dallas. Our unique value lies in 25+ years of experience, personalized attention, and transparent pricing. We provide clear explanations of legal options and honest case assessments, avoiding false hope or client expectation pandering. Instead, we focus on realistic outcomes and genuine care for your interests.
If you’re in Lakewood, White Rock, or Forest Hills and dealing with spousal support disputes, turn to our Dallas spousal support lawyer for guidance. For high-net-worth cases in Grand Prairie or Duncanville, visit our lawyer page. We serve clients across Dallas County, ensuring informed decisions based on facts.
Areas We Serve: Comprehensive Family Law Support in Dallas and Beyond
Our practice extends beyond central Dallas to include Irving, Garland, Richardson, Mesquite, DeSoto, Grand Prairie, Lakewood, Highland Park, Forest Hills, White Rock, North Dallas, Farmers Branch, Cockrell Hill, Lancaster, Seagoville, and Duncanville. No matter your location, if you’re searching for a “divorce attorney near me” or an “affordable divorce lawyer in Dallas”, we’re here to help with child support matters—check our Dallas child support attorney.
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Ready to Take the Next Step? Schedule Your Consultation Today
Facing family violence or doesn’t have to be overwhelming. As your trusted Dallas divorce attorney, I’ll provide the transparent guidance you need to protect your future. Contact us now for a no-obligation no-hassle consultation. Let’s work together toward a resolution that prioritizes your safety and well-being.
