Ms. Hanson-Parmer appealed a trial court’s decision to give Mr. Parmer parenting time with his non-biological son (D). The parties had three children during their marriage. The fourth child (D) was born during the parties’ separation. A non-parent is only entitled to visitation with a child if he can demonstrate a child-parent relationship. Under ORS 109.119, the Court must look to the six months prior to the filing of the action and determine if the non-parent resided with the child in the same household or otherwise provided for the child on a day-to-day basis. Although Mr. Parmer had regular visits with D every week (from 9:00 am Tuesday until 8:00 pm Wednesday), this does not satisfy the requirements of ORS 109.119(10). Based on these facts, the Court of Appeals ruled that the trial court had erred in awarding Mr. Parmer parenting time with D. The case is reversed and remanded to reflect the same.

Read Liana Martha Hanson-Parmer v James Michael Parmer.

In this case, Ms. Van Buskirk, a reporter for the Portland Tribune, sought a Stalking Protective Order against Mr. Ryan. The two met at an open house for the Tribune, but never met after that. However, Ryan began sending letters and e-mails to establish a romantic relationship with Van Buskirk. Despite repeated requests to stop attempting to contact her, Ryan continued to send correspondence, some of which include references to her young son. Ryan also sent correspondence to Van Buskirk’s parents, comparing the two to Romeo and Juliet. He also attempted to reach her by phone at work and home and went to her workplace on repeated occasions. The Court of Appeals found that the communications themselves were not a sufficient basis for the entry of the stalking protective order because there were no unequivocal threats of violence. However, the Court held that the communications provided context for Ryan’s other non-communicative contacts (i.e., going to her place of employment). In light of the many communications, the Court found that these non-communicative contacts formed a pattern of behavior that made Van Buskirk’s apprehension reasonable. The Stalking Protective Order was enforced.

Read Van Buskirk v. Ryan.