Domestic violence injunctions are powerful. They can immediately cut off a parent’s contact with a child, override existing time-sharing arrangements, and dramatically alter the balance of power in an already tense family situation.

Because of that power, Florida law sets a clear threshold for when an injunction is allowed. A recent decision from Florida’s Sixth District Court of Appeal, Negron v. Bonilla (January 9, 2026), is an important reminder of what that threshold is—and what it is not.

The Case, in Plain English

In Negron v. Bonilla, a mother sought a domestic violence injunction on behalf of her minor child, asking the court to stop the father’s visitation entirely. The mother testified that she feared the father would abuse the child. The child also testified and expressed fear of her father, describing him as having a temper and referencing a single incident from years earlier when he hit her over a sports issue.

The trial court was clearly concerned. It focused heavily on the child’s fear, the emotional stress of being caught between parents, and the need for therapeutic intervention. Based on those concerns, the court entered a six-month domestic violence injunction that prohibited contact, except for supervised therapeutic sessions.

On appeal, the Sixth District reversed.

Why the Appellate Court Reversed

The appellate court did not minimize the child’s fear. It did not say the situation was healthy. And it did not criticize the trial judge’s concern for the child’s emotional well-being.

What it said—firmly and clearly—was this: fear alone is not domestic violence.

Under Florida law, an injunction for protection against domestic violence requires evidence of either:

1. an actual act of domestic violence, or
2. reasonable cause to believe that domestic violence is imminent.

“Domestic violence” is not a vague concept. It is defined by statute and includes specific criminal acts such as assault, battery, stalking, or other offenses resulting in physical injury.

In Negron, the appellate court found that:
• there was no recent act of violence,
• no evidence of imminent violence, and
• no factual findings by the trial court identifying conduct that met the statutory definition of domestic violence.

The trial court’s ruling was based on fear and emotional distress—not on legally sufficient evidence of domestic violence. That was not enough.

Why This Case Matters to Parents

This decision highlights a line that family courts must respect, even in emotionally charged cases.

Family courts absolutely have tools to address:
• high conflict between parents
• emotionally harmful dynamics
• the need for therapy or supervised contact

But a domestic violence injunction is not a general “best interests” remedy. It is an extraordinary measure with serious legal consequences, and it requires specific proof.

For parents, this case carries two important lessons.

First, injunctions are not supposed to be used as a substitute for custody litigation. Courts cannot use a domestic violence injunction simply to manage fear, discomfort, or poor communication between parents.

Second, allegations matter—but evidence matters more. Courts must base injunctions on legally defined conduct, not generalized concerns or emotional reactions.

Why Experienced Counsel Makes a Difference

Cases like Negron v. Bonilla are often decided in fast-moving hearings, sometimes with one or both parties appearing without lawyers. Trial judges are forced to make difficult decisions in real time, often with limited records.

The appellate court’s reversal underscores how important it is to:
• understand the statutory definitions
• distinguish between emotional harm and legally defined violence
• preserve the record for review
• frame arguments in a way that matches what the law actually requires

These are not intuitive distinctions for people in the middle of a family crisis. They are legal distinctions that only show their importance after the fact—sometimes after contact has already been cut off.

The Takeaway

Negron v. Bonilla is not a case about ignoring a child’s fear. It is a case about using the right legal tool for the right problem.

Domestic violence injunctions are meant to address violence or imminent violence. When courts stretch them beyond that purpose, appellate courts step in.

For parents involved in high-conflict family disputes, this case is a reminder that outcomes often turn not just on what is said in court, but on how the law defines and limits the court’s power. Understanding those limits—and knowing how to argue them—can make the difference between a temporary concern and a life-altering order.