“…Although statute provides guidance, the interpretation and application of DVPO firearm restrictions is left to judges' discretion. Research from California (Vittes & Sorenson, 2006), Florida (Lucken & Rosky, 2016;Lucken et al, 2015), New York (Webster et al, 2010), Arizona (Wallin & Durfee, 2020), Texas (Lynch et al, 2021), and a large Southwestern city (Bejinariu, 2016) collectively suggests that only a small proportion of DVPO plaintiffs who report firearm violence, weapon threats, or who request defendant gun restrictions ultimately receive a full DVPO with firearm restrictions. In fact, even if a plaintiff explicitly requests firearm surrender in a state where that provision was available, research suggests that a surrender injunction is only included in 11-50% of these orders (Wallin & Durfee, 2020;Webster et al, 2010).…”