Firearm Removal,Judicial Decision-Making,and Domestic Violence Protection Orders

Abstract

Firearms in situations of domestic violence (DV) are particularly lethal. Although firearms present a public health concern nationally, some states, such as Arizona, have especially high rates of intimate partner homicide (IPH). Despite empirical findings that state-level firearm removal policies significantly reduce rates of IPH, little is known about the factors shaping judicial decisions to implement these provisions at the local level. This study analyzes petitioner and judicial decision-making about firearm removal in cases of civil DV protection orders (POs). We use a sample of 580 PO filings from the DV protection order database (Durfee 2019). Petitioners request firearm removal in 49.6% of PO petitions, and judges include state-level firearm removal as a provision in 31.0% of POs that are granted. Of the 580 petitioners who request firearm removal and receive an issued PO, judges grant firearm removal 50.1% of the time. Findings reveal that judges are more likely to grant firearm removal when PO petitions contain mentions of physical violence, threats to kill the petitioner, and allegations that the respondent owns a gun, controlling for all demographics, incidence characteristics, and allegations about the respondent. Furthermore, judges are less likely to grant firearm removal when petitioners allege that the respondent has mental health issues. The results are discussed within the context of judicial discretion and U.S. firearm legislation.

Introduction

Firearms within the United States pose a uniquely lethal threat to survivors of domestic violence (DV) and intimate partner violence (IPV). Women's risk of intimate partner homicide (IPH) victimization increases fivefold when an intimate has access to firearms (Campbell et al. 2003) with firearm access common among samples of IPH offenders (Glass et al. 2008). Federal law has sought to curtail IPH rates by preventing individuals subject to an active DV civil protective order (PO) from purchasing or possessing firearms (18 U.S.C. § 922). Despite federal efforts, a study by Zeoli and colleagues (2019) found that only 29 states and the District of Columbia had adopted laws prohibiting firearms for those subject to DV POs.

POs provide a legal means of limiting contact between individuals in situations of DV, aiming to increase victim safety and reduce the threat of harm and DV for those involved (DeJong and Burgess-Proctor 2006; Eigenberg et al. 2003; Keilitz 1994; Logan and Walker 2010; Richards et al. 2018). Unlike criminal no contact orders, civil POs are petitioner (person filing for a PO) initiated, and petitioners may request various forms of relief, including prohibiting a respondent (person subject to a PO) from purchasing or possessing firearms (DeJong and Burgess-Proctor 2006). As they are obtained in the civil courts, POs have a lower evidentiary standard than is used in the criminal justice system, and judges hold the ultimate discretionary power in determining whether to grant a PO and subsequent forms of relief.

Although decisions to grant POs are subject to judicial discretion, studies have found that judges are more likely to grant POs to women (Basile 2005; Durfee 2011; Kingsnorth et al. 2013; Muller et al. 2009), petitioners who have attorneys (Durfee 2009), and those who allege sexual assault, that a child witnessed the abuse, and that the respondent threatened others (Vittes and Sorenson 2006). The marital status of the parties has produced mixed results, with evidence suggesting marriage is negatively (Kingsnorth et al. 2013) and positively (Gondolf et al. 1994) related to receiving a PO.

Judges are more likely to deny a PO if the petitioner has a pending custody case and files on behalf of children, the respondent is male, the parties are not in an intimate relationship (Jordan et al. 2008), the respondent is employed, contests the order, has sought an order previously, and has an attorney (Lucken et al. 2014). For Vittes and Sorenson (2006), severity of abuse alleged, and firearms did not have a significant impact on granting a PO.

Removing firearms from potentially dangerous abusers is vital to providing petitioner safety, as filing for a PO increases one's risk for reabuse, injury, and homicide (Campbell et al. 2003; Messing et al. 2014). Petitioners often file for a PO after a violent incident (Carlson et al. 1999; Harrell and Smith 1996), specifically women who experience an extremely violent event or are stalked (Messing et al. 2016). Concerns for personal safety—fear that their abuser may seek retaliation for attempting to limit their firearm access (Frattaroli and Teret 2006; Logan and Lynch 2018; Vittes et al. 2013; Wintemute et al. 2015), and apathy toward the criminal justice system (Frattaroli and Teret 2006) shape petitioner decisions to request firearm removal.

Qualitative studies assessing criminal justice response to firearm removal reveal system shortcomings. Vittes and colleagues (2013) find that 10 of the 17 female petitioners interviewed reported the respondent had access to a firearm, but 59% reported that the judge did not ask whether the respondent owned guns (p. 609). Webster and colleagues (2010) found that 82 petitioners who received a PO reported the respondent owned firearms; of these 82, 45% requested firearm removal. Of the 15% who reported firearm victimization, less than half were granted the firearm relief they requested. Furthermore, 28% of judges in Fleury-Steiner et al.'s (2017) study failed to explain or mention the firearm prohibition to petitioners, limiting petitioner awareness of this provision as an available safety measure (Webster et al. 2010).

Despite differential justice system implementation, robust evidence that state-level firearm removal laws are associated with a reduction in both overall and firearm-related IPH rates exists (Diez et al. 2017; Vigdor and Mercy 2003, 2006; Zeoli and Webster 2010; Zeoli et al. 2018). Vigdor and Mercy (2003, 2006) found that the introduction of PO laws led to a 7% decline in female IPHs, and Zeoli and Webster (2010) found a 25% decrease in firearm IPH risk in states allowing warrantless arrest for PO violations and prohibiting firearm possession through POs.

Diez et al. (2017) found a reduction in state-specific rates of IPH and firearm IPH in states with laws on IPV restraining orders prohibiting the possession of firearms and specifying surrender details. Consistent with these prior findings, Zeoli et al. (2018) found that states prohibiting individuals subject to DV POs from possessing firearms had a subsequent reduction in IPH rates.

Although evidence reveals the efficacy of firearm removal laws, relatively little is known about which factors impact a judge's decision to grant firearm removal. Addressing this gap in the literature, this article analyzes judicial decision-making around firearm removal provisions on civil POs. We provide a quantitative assessment of the implementation and decision-making process around state-level firearm removal requests and address (1) how frequently petitioners request firearm removal on issued orders of protection, (2) how often judges grant state-level firearm removal, and (3) which factors influence whether a judge invokes one's request for firearm removal.

Materials and Methods

This study uses data from the DV protection order database (DV-POD; Durfee 2019). The DV-POD contains 1388 PO petitions filed in 2015 in an Arizona court of limited jurisdiction (municipal and justice courts). To be included in the DV-POD, both the petitioner and respondent must be >18 years old and have a domestic relationship, including married/formerly married, cohabiting/formerly cohabiting, romantic or dating/formerly romantic or dating, child in common/pregnancy, or relatives.

When filing for a PO, petitioners have the option of requesting that a judge prohibit the respondent from possessing, receiving, or purchasing firearms (Ariz. Rev. Stat. § 13-3602 section G, clause 4). Judges can order state-level firearm removal during the ex parte hearing (at which only the petitioner attends) if they find the respondent poses a “credible threat to the physical safety of the petitioner” or other parties listed on the PO (Ariz. Rev. Stat. § 13-3602 (G)(4)).

In determining whether to issue or deny a PO, judges must find “reasonable cause” to believe the respondent has or may commit an act of DV (Ariz. Rev. Stat. § 13-3602(G)(4)). If the judges find insufficient evidence to grant the order, they can deny the request or schedule a hearing with both parties present to determine whether there are grounds for issuance (17B A.R.S. Rules Protect. Ord. Proc., Rule 23). Orders issued at the ex parte hearing are akin to that of a final PO and is effective for 1 year upon service (Ariz. Rev. Stat. § 13-3602(G)(4)). We use a subsample of 580 cases where the petitioner requested firearm removal pursuant to Arizona Revised Statute § 13-3601 and were granted a PO.

Research site

Firearm IPH is particularly concentrated in the state of Arizona, with 61% of IPHs reveals from 2003 to 2012, committed with a firearm (Center for American Progress 2014), and Arizona's intimate partner gun homicide rate exceeding the national average by 45% from 2009 to 2013 (Everytown for Gun Safety 2015). Although Arizona's “Constitutional Carry” provision, which gives U.S. citizens >21 years old the “individual” right to bear arms free from permit, license, or registration requirements (Ariz. Rev. Stat. § 13-3112), has been criticized for facilitating gun violence with their lax regulations, POs provide a means of limiting firearm access.

In Arizona, judges have a large degree of discretion in determining whether prohibiting a respondent from “possessing or purchasing firearms” is warranted (Ariz. Rev. Stat. § 13-3602; DeJong and Burgess-Proctor 2006). Prior qualitative research illustrates the complexity of judicial decision-making processes by demonstrating that personal attitudes around DV, gun rights, and the courts shape these decisions (Frattaroli and Teret 2006). As the lethal intersection of firearms and DV is particularly concentrated in Arizona, it is a unique state of analysis, with gun-supportive legislation and policy, and heightened rates of DV gun homicide.

Measures

Dependent variable

The dependent variable for this analysis is a dichotomous variable indicating whether the judge granted the removal of firearms pursuant to Ariz. Rev. Stat. § 13-3602(G)(4) (1 = yes, 0 = no). Table 1 illustrates that of the petitions included in this analysis, 50% of petitioners who requested firearm removal (n = 291) were granted these requests.

Table 1.

Descriptive Statistics of Issued Protection Orders with Firearm Removal Requests (n = 580)

Variable	Mean	SD
Judge granted firearm removal	0.50	0.50
Demographic characteristics
Female petitioner	0.81	0.40
Female respondent	0.19	0.39
Age of petitioner in years	39.17	14.05
Age of respondent in years	37.11	11.86
Respondent's race and ethnicity
White NH^a	0.56	0.50
Black NH	0.15	0.36
Hispanic	0.24	0.43
Other race^b	0.04	0.20
Petitioner and respondent relationship
Married^a	0.20	0.40
Live together	0.43	0.50
Child in common	0.07	0.26
Related	0.13	0.34
Romantic, sexual, or dating relationship	0.16	0.37
Abuse characteristics
Verbal abuse	0.28	0.45
Intimidation	0.48	0.50
Physical abuse	0.49	0.50
Strangulation	0.10	0.30
Threatened to kill petitioner	0.20	0.40
Threatened to kill self	0.06	0.24
Threatened petitioner with gun	0.07	0.26
Allegations of respondent behavior
Petitioner reportedly fearful of respondent	0.24	0.43
Gun ownership	0.18	0.38
Weapon ownership	0.12	0.32
Mental health issues	0.17	0.38
Alcohol use/addiction	0.16	0.37
Drug use/addiction	0.20	0.40
Arrest history
Petitioner prior DV^c charge or arrest	0.03	0.16
Respondent prior DV charge or arrest	0.28	0.45

Reference variable.

Combined Asian Pacific Islander NH and American Indian/Alaska Native NH.

DV as defined in Arizona Revised Statutes Title 13. Criminal Code § 13-3601.

DV, domestic violence; NH, non-Hispanic; SD, standard deviation.

Independent variables

A series of independent variables capturing the demographic characteristics of the petitioner and respondent, types of abuse alleged, and other allegations made by the petitioner were created.

Demographic characteristics

The petitioner and respondent's gender (1 = female, 0 = male), the age of the petitioner in years, the respondent's race and ethnicity, and relationship status were included in the model. The majority (81%) of petitioners in the sample who received a PO and requested firearm removal are women, and the average petitioner age is 39.17 years. The majority of respondents in the sample are white non-Hispanic (56%), with 15% black non-Hispanic, 24% Hispanic (all races), and 4% are of another race, which included Asian Pacific Islander and American Indian/Alaska Native non-Hispanic. These racial groups were combined due to the small number of respondents in the sample who were members of these groups.

An act meeting the legal definition of DV in Arizona must have been threatened or actualized against the petitioner, their children, or vulnerable adults (Ariz. Rev. Stat. § 13-3623) under the respondent's care. Specifically, offenses only constitute DV if they involve an alleged victim and defendant who meet the state relationship criteria. Twenty percent of the petitioners in the sample were currently or previously married to the respondent, 43% currently or previously lived together, 7% had a child in common or were pregnant with the other party's child, 13% were related, and 16% currently or previously had a romantic, sexual, or dating relationship.

Incident characteristics

The presence (1) or absence (0) of specific abuses listed in Arizona Revised Statute § 13-3601 were coded if alleged by the petitioner. Offenses included intimidation (defined by Arizona Revised Statute § 13-1202 as threats to cause physical injury or serious damage to property of another), threats to kill the petitioner, threats to kill oneself (the respondent), threats with a firearm (both actual use of, and threats with, a firearm), and acts of physical violence. Physical violence, prohibited under Arizona Revised Statute § 13-3601, included physical acts such as harming with open hands, closed fists, pushing, kicking, strangulation, restraint, biting, scratching, smothering, or shoving. Cases of sexual violence were omitted from this analysis due to the infrequency of sexual violence disclosures among petitioners in PO filings.

As shown in Table 1, the most commonly reported forms of DV are physical abuse (49%) and intimidation (48%). Less common are allegations of verbal abuse (28%), threats to kill the petitioner (20%), strangulation (10%), and the respondent threatening to kill themselves (6%). Threats with a firearm were alleged in 7% of cases.

Types of allegations made by the petitioner about the respondent

Petitioners indicated that 18% of respondents owned a gun and 12% owned another type of weapon. Seventeen percent of petitioners alleged the respondent has mental health issues, 16% reported the respondent is addicted to alcohol, and 20% said that the respondent was addicted to drugs. Three percent of petitioners admitted that they had been arrested for or charged with DV, and they said that 28% of respondents had a prior DV charge or arrest.

Analytic technique

To explore the relationship between state-level firearm removal and individual and incident characteristics, a series of multivariate logistic regressions were conducted. The use of logistic regressions is appropriate as the dependent variable is nominal and contains two mutually exclusive categories of interest (granting or denying state-level firearm removal). Information obtained from the data aim to explore which factors prove relevant for judicial actors as it pertains to firearm removal on POs.

Results

Of the 1170 issued orders of protection 580 (49.6%) petitioners requested firearm removal, and 291 (50.1%) of these petitioners had a judge grant this relief. Table 2 reveals which factors shape judicial decisions to grant or deny this provision. Model 1 finds that women are significantly more likely to receive firearm removal (odds ratio [OR] = 1.71), and petitioners who lived with the respondent now or in the past are less likely to have removal granted, as compared with those who are married/formerly married (OR = 0.63).

Table 2.

Multivariate Logistic Regression Models Predicting Granting Firearm Removal (n = 580)

	Model 1 OR (SE)	Model 2 OR (SE)	Model 3 OR (SE)	Model 4 OR (SE)
Demographic characteristics
Female petitioner	1.71 (0.42)^*			1.55 (0.41)
Female respondent	0.66 (0.16)			0.75 (0.20)
Mean age of petitioner	0.99 (0.01)			1.00 (0.01)
Respondent race and ethnicity
Black NH	1.01 (0.27)			0.92 (0.25)
Hispanic	1.18 (0.25)			1.11 (0.25)
Other race^a	0.78 (0.34)			0.78 (0.37)
Petitioner and respondent relationship
Live together	0.63 (0.15)^*			0.71 (0.18)
Child in common	0.81 (0.31)			1.01 (0.41)
Related	0.82 (0.26)			1.12 (0.39)
Romantic, sexual, or dating	0.84 (0.24)			1.00 (0.31)
Abuse allegation characteristics
Verbal abuse		0.86 (0.17)		0.89 (0.19)
Intimidation		1.24 (0.23)		1.26 (0.25)
Physical abuse		1.67 (0.31)^**		1.67 (0.34)^*
Strangulation		1.52 (0.48)		1.38 (0.46)
Nature of threats
Threatened to kill petitioner		1.90 (0.47)^**		2.08 (0.55)^**
Threatened to kill self		2.13 (0.86)		2.10 (0.89)
Threatened petitioner with gun		3.77 (1.67)^**		2.55 (1.27)
Allegations of respondent behavior
Petitioner “fearful” of respondent			0.99 (0.20)	0.99 (0.22)
Gun ownership			2.98 (0.73)^***	1.90 (0.55)^*
Weapon ownership			1.01 (0.29)	0.82 (0.25)
Mental health issues			0.61 (0.15)^**	0.59 (0.15)^*
Alcohol use/addiction			0.83 (0.21)	0.81 (0.21)
Drug use/addiction			0.80 (0.19)	0.77 (0.19)
Arrest history
Petitioner prior DV^b charge or arrest				1.58 (0.90)
Respondent prior DV charge or arrest				1.10 (0.23)
Constant	1.34 (0.58)	0.55 (0.09)^***	0.98 (0.11)	0.59 (0.30)
Pseudo R square	0.03	0.07	0.04	0.11

Combined Asian Pacific Islander NH and American Indian/Alaska Native NH.

DV as defined in Arizona Revised Statutes Title 13. Criminal Code § 13-3601.

p ≤ 0.05; ^**p ≤ 0.01; ^***p ≤ 0.001.

OR, odds ratio; SE, standard error.

Model 2 investigates the association between allegations of abuse and firearm removal. Allegations of physical abuse, threats to kill the petitioner, and threatening the petitioner with a firearm significantly impact a judge's decision to issue firearm removal. Judges are more likely to grant firearm removal when the petition contains allegations of firearm threats (OR = 3.77), physical abuse (OR = 1.67), and threats to kill the petitioner (OR = 1.90).

When considering the impact of allegations of other respondent behaviors on judicial decisions, Model 3 reveals that judges are significantly more likely to grant firearm removal when the petitioner alleges the respondent owns a firearm (OR = 2.98). Interestingly, allegations of mental health issues are negatively associated with a judge granting firearm removal (OR = 0.61).

Taking all individual and incidence characteristics, as well as other allegations about the respondent into account, the full model (Model 4) illustrates that judges are significantly more likely to grant firearm removal in the presence of allegations of physical violence (OR = 1.67), threats to kill (OR = 2.08), and the respondent owning a firearm (OR = 1.90). Consistent with Model 3, judges are significantly less likely to issue firearm removal when the petitioner alleges that the respondent has mental health issues (OR = 0.59). The full model (Model 4) explains 11% of the variation in judicial decisions to grant firearm removal requests.

Discussion

Judges in Arizona are instructed to order firearm removal upon a finding of “credible threat to the physical safety of the petitioner” (Ariz. Rev. Stat. § 13-3602 (G)(4)). Within this study, only 31% of issued orders met this standard. Of the 580 petitioners requesting the judge order the respondent “NOT to possess firearms or ammunition” “because of the risk of harm” present (Arizona Approved Protective Order Forms Administrative Directive Nos. 2013-03, 2006-01, 2007), only 50% had removal granted. Judges interpreted “credible threat” as physical violence, threats to kill, and firearm ownership. These findings reveal that Arizona judges are taking into account the lethality of firearm access in situations of DV (Campbell et al. 2003), while ignoring other petitioner allegations of harm.

Judges did not deem respondents to be a “credible threat” to petitioner safety when they were alleged to have mental health issues. This finding is cause for concern given the increased awareness around the intersection of firearms and mental health, and legislative movement toward the adoption of Extreme Risk POs. To the authors' knowledge, this is the first study to assess the impact of allegations of mental health on firearm removal on POs. Future studies are needed to expand upon these findings and investigate how judges interpret claims of mental health status in determining whether to implement firearm removal.

Relative to studies on PO decision-making, firearm removal decisions rested primarily on indications of physical violence and threats. Demographic factors, such as relationship status and gender, are not related to firearm removal decisions (Basile 2005; Durfee 2011; Kingsnorth et al. 2013; Muller et al. 2009). Unlike Vittes and Sorenson's (2006) assessment of PO granting overall, when it comes to firearm removal clauses severity of abuse and gun ownership were significant predictors of granting removal. Prior qualitative studies have found that firearm removal is irregularly implemented (Webster et al. 2010) and inconsistently communicated to petitioners (Fleury-Steiner et al. 2017; Webster et al. 2010), and this quantitative study finds similar rates of issuance.

This study is not without limitations. The low variance explained by Model 4 deserves further exploration and indicates that explanatory variables were missing from this analysis. Arizona's ex parte PO process limits the applicability of federal firearm law. Generalizability is limited due to Arizona's specific state laws and PO process, with future studies needed to assess factors shaping firearm removal decision-making in other states.

Despite these limitations, this study offers insight into the judicial decision-making process around firearm removal. Understanding the interpretation and implementation of firearm removal policies is key to assessing how judges navigate providing life-saving provisions and determining when to remove someone's right to bear arms. Firearm violence against female intimates can be quelled through the implementation of these provisions, and factors shaping one's ability to have this relief provided are vital to ensuring further victim safety measures are in place.

Conclusion

Civil DV POs offer a means of gun control in a political climate that continues to further gun rights, particularly in the state of Arizona. The ability to limit a respondent's access to firearms is a crucial provision on POs, but competing conceptions around firearms and “credible threat” shape the implementation of this provision. Prior studies have extensively illustrated that petitioners seeking an order of protection are doing so in the face of severe violence, and their act of seeking out the criminal justice system in this manner is further accentuating that risk (Carlson et al. 1999; Harrell and Smith 1996).

Firearm removal provisions have the ability to afford protection for particular individuals and reduce overall rates of IPH and firearm IPH overall (Diez et al. 2017; Vigdor and Mercy 2003, 2006; Zeoli and Webster 2010; Zeoli et al. 2018). Findings reveal that only 50% of those who requested this potentially life-saving provision received this relief. Without implementation, these laws lack the ability to effectively function and reduce homicide.

Footnotes

Acknowledgments

We thank the anonymous reviewers at Violence and Gender for their comments, as well as Felicity Snyder, Jayde Ely, John Costello, Kellie Herson, Victoria Namuggala, Vanessa Martinez-Morales, Natasha McLain, Trisha Dasgupta, Taylor Thompson, Katie Knoepker, Cristian Torres, Anna Vazar, Olivia Lyles, and Sara Sapia.

Disclaimer

The opinions, findings, and conclusions or recommendations expressed in this publication are those of the authors and do not necessarily reflect those of the Department of Justice.

Author Disclosure Statement

No competing financial interests exist.

Funding Information

This project was supported by Award No. 2015-IJ-CX- 0013, awarded by the National Institute of Justice, Office of Justice Programs, U.S. Department of Justice.

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Ariz. Rev. Stat. § 13-3112. Retrieved from https://www.azleg.gov/ars/13/03112.htm

Ariz. Rev. Stat. § 13-3601. Retrieved from https://www.azleg.gov/ars/13/03601.htm

Ariz. Rev. Stat. § 13-3602(G)(4). Retrieved from https://www.azleg.gov/ars/13/03602.htm

Ariz. Rev. Stat § 13-3623. Retrieved from https://www.azleg.gov/ars/13/03623.htm

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