In the case of Elliott v. Commonwealth, the Virginia Supreme Court, in a published opinion ruled that a father did not violate a protective order when he stood on one street, one block from the house of his child's mother, outside of his vehicle, with an unobstructed view to the house and his child's mother, speaking on his phone and making various gestures including pointing at the residence. This is even after he told the mother on the court house steps that he was going to "beat them home" after unsuccessfully pursuing a protective order against the mother.
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