According to the Pennsylvania Superior Court, the Protection from Abuse Act allows trial courts to grant broad relief to protect victims of domestic violence from those who perpetrate such abuse. Under Section 6108 of the Protection from Abuse Act: “the court may grant any protection order or approve any consent agreement to bring about the cessation of abuse of the plaintiff or minor children.” Further, the Protection from Abuse Act provides that: “any parent, adult household member, or guardian ad litem may seek relief under this chapter on behalf of a minor children, by filing a petition with the court alleging abuse by the defendant.”

Section 6114.1 of the Protection from Abuse Act states: “a plaintiff may file a petition for civil contempt with the issuing court alleging that the defendant has violated any provision of an order or court-approved agreement issued under this chapter or a foreign protection order.” Because 6114.1 only states that a “plaintiff” may file a petition for civil contempt, may a “defendant” file a petition for civil contempt in a protection from abuse matter? This issue was addressed head-on in the recent case of Adams ex rel. T.E.A. v. Adams, ___ A.3d ___, 24 Pa. Super. 240 (Oct. 17, 2024).