From Delaware Family Court Judge Eliza Hirst's order in M— R— v. C— H—, decided Mar. 4 but just posted on Westlaw:
On August 18, 2025, the parties entered into a stipulated custody agreement wherein they shared joint legal custody, Mother had primary residential placement of the child, and Father had weekly contact with N---. On October 17, 2025, Mother sought and secured an emergency ex parte Protection from Abuse ("PFA") order against Father. The order directed Father not to contact Mother, approach her, or otherwise "threaten, molest, attack, harass[,] or commit any other act of abuse against" her or N--- . It was initially set to expire on November 17, 2025, but it was later extended to January 14, 2026. On December 16, 2025, Mother filed a motion seeking to obtain certain therapy records. Over the next two days, Father secured a lawyer, responded to that motion, moved for interim relief, sought his own PFA, and filed the present custody-modification petition.
On December 19, 2025, with the ex parte PFA in effect and all those petitions and motions pending, Father posted the single video specifically identified in Mother's Motion to Restrict Public Postings. The video showed N--- walking with Father's help (though only his legs and arms were visible), and it bore the caption, "Thx for joining. If you have any legal advice for dealing with manipulative / emotional abusers please share I'd really appreciate it."
The parties both appeared on January 14, 2026, for the scheduled trial on their PFA cross-petitions, but Father ultimately agreed to dismiss his petition and sign a consent order in Mother's favor. The consent order proscribed precisely the same conduct as the ex parte, except that Father was permitted to communicate with Mother on Our Family Wizard about N---'s well-being.
About two weeks later, after Mother found the video now at issue, she filed three motions with nearly identical allegations: (1) a motion to hold Father in contempt of the ex parte PFA, (2) a motion to extend the consent PFA and modify it to explicitly prohibit social-media posts about "any Family Court litigation, Petition[er,] and their child in common," and (3) the present Motion to Restrict Public Postings….
