Bethany Lewis sought a protective order under Georgia's Family Violence Act against her estranged husband after a history of harassment, threats, and physical violence. The trial judge found Lewis's testimony about that history extremely credible but dismissed the petition because her most recent physical assault had occurred nearly a year earlier. The Georgia Court of Appeals vacated and remanded. It held that OCGA § 19-13-3 requires a petitioner to prove that family violence occurred at some unspecified time in the past and may occur again at some unspecified time in the future. The statute does not impose an absolute requirement that the past violence be reasonably recent. Recency may bear on the likelihood of future violence, but it is not a standalone statutory prerequisite. The court therefore concluded that the trial court abused its discretion by treating a reasonably recent act as mandatory. It also explained that a county form could not add substantive requirements absent from the statute. The case returned for proceedings under the correct legal standard.