California matters
California Coercive Control Expert Witness: Family Code 6320 and DVRO Matters
Pattern analysis of written records for domestic violence restraining order and custody proceedings under the California Family Code.
California Family Code section 6320, subdivision (c), defines disturbing the peace of the other party to include coercive control, which the statute describes as “a pattern of behavior that in purpose or effect unreasonably interferes with a person’s free will and personal liberty.” A domestic violence restraining order (DVRO) may rest on that pattern.
The Legislature wrote coercive control into section 6320 through SB 1141 (2020) and amended the section through SB 374 (2021) and SB 50 (2025). AB 2534, Chapter 950, Statutes of 2026, signed September 30, 2026, adds interfering with a court proceeding to the section 6320 examples, effective January 1, 2027.
A statute that names coercive control does not finish the work. The hard part is showing the pattern in a longitudinal record. Carlton Research, LLC analyzes that record for attorneys in DVRO, custody, and criminal matters.
What Family Code 6320 Lists as Coercive Control
Section 6320(c) lists examples of coercive control, without limitation, when the conduct is unreasonable:
- Isolating the other party from sources of support.
- Depriving the other party of basic necessities.
- Controlling, regulating, or monitoring movements, communications, daily behavior, finances, economic resources, or access to services.
- Compelling conduct or abstention by force, threat of force, or intimidation, including threats based on actual or suspected immigration status.
- Reproductive coercion.
The statute reaches conduct committed directly, indirectly, or through a third party, including by telephone, online accounts, text messages, and internet-connected devices.
The above behaviors are examples only. A broader range of coercive control behaviors are successfully argued in court. See our appeals tracker.
How to Prove Coercive Control in California: DVRO Evidence
Section 6320(c) frames coercive control as a pattern, so DVRO evidence needs to show conduct across time. Carlton Research analyzes text messages, email, parenting-app messages, call logs, location data, and financial records in sequence across a disclosed window. A pattern must satisfy four prongs: repetition, relatedness, continuity, and asymmetry. Both parties’ records are analyzed under identical rules, and conflict of comparable intensity on both sides fails the asymmetry prong.
Background reading: evidence on coerced debt and economic abuse and linguistic markers of coercive control in digital communication.
Family Code 3044 and Custody
Family Code section 3044 creates a rebuttable presumption that awarding sole or joint physical or legal custody to a party found to have perpetrated domestic violence within the previous five years is detrimental to the best interest of the child. Under section 3044(c), perpetrating domestic violence includes behavior such as disturbing the peace of another for which a court may issue an ex parte order under section 6320. Section 3044(e) bars a domestic violence finding based solely on a child custody evaluator’s conclusions or a Family Court Services recommendation, and directs the court to consider relevant, admissible evidence the parties submit.
Carlton Research reports whether a pattern of coercive control is present; the court applies section 3044. Post-separation records receive the same test; see why coercive control often intensifies after separation.
Reporting Standards and Evidence Code 1107
In a criminal action, Evidence Code section 1107 admits expert testimony by the prosecution or the defense on intimate partner battering and its effects, except when offered against a defendant to prove the acts of abuse that form the basis of the charge.
In every forum, the report states the method, the decision rules from The Codebook for Identifying Coercive Control in Longitudinal Artifacts, and the application of those rules to the record, so opposing counsel and the court can test each step. Admissibility background: how expert testimony functions in coercive control cases.
Deliverables
- Written report. Findings on each prong, the records reviewed, the disclosed timeframe, and the limits of the record.
- Declaration. A sworn statement of findings for a DVRO or custody filing.
- Testimony. Hearing, deposition, or trial testimony.
What Carlton Research Does Not Do
- Does not evaluate custody or recommend parenting time.
- Does not diagnose any party or perform clinical evaluations.
- Does not guarantee an outcome. The court decides what the evidence shows.
California Service
Carlton Research, LLC is located in Laguna Beach, California, and takes California matters when the record and the standard are a fit. Carisa Carlton, M.A., Coercive Control Expert Witness & CEO Carlton Research, LLC, conducted an 18-month, grant-funded courtroom ethnography at the Lamoreaux Justice Center in Orange County. Other jurisdictions: Regions and domestic violence expert witness.
Questions Counsel Ask
Does Family Code 6320 require physical violence for a DVRO?
No. Section 6320(c) includes coercive control in disturbing the peace, and Family Code section 6203(b) provides that abuse is not limited to the actual infliction of physical injury or assault. Whether the evidence supports an order remains a question for the court.
What DVRO evidence shows coercive control?
Contemporaneous records the parties created across time. The four-prong test asks whether the coercive conduct shows repetition, relatedness, continuity, and asymmetry.
Will the report recommend custody under Family Code 3044?
No. The report states whether a pattern of coercive control is established in the disclosed record. The court decides whether section 3044 applies. More answers appear on the coercive control expert witness FAQ.
Nothing here is legal advice or a determination in any specific case.