S.D. and G.D. are divorced and share a child together. After a physical altercation during S.D.’s visit with the child, G.D. sought a protective order. The Starke Circuit Court granted G.D.’s petition, but the Court of Appeals reversed, finding that S.D. was not a credible threat to G.D.’s safety or the safety of a household member, and the trial court erred by not balancing G.D.’s need for protection against the burden imposed by the protective order. S.D. v. G.D., 195 N.E.3d 406 (Ind. Ct. App. 2022), vacated. The Indiana Supreme Court has granted transfer and assumed jurisdiction over the case.