Disputes between former partners don’t always end with the breakup—sometimes they escalate into harassment campaigns that threaten safety, reputation, and peace of mind. In Honacher v. Uhlhorn (2025), the North Carolina Court of Appeals affirmed that Domestic Violence Protective Orders (DVPOs) can apply even when the abuse takes the form of financial intimidation and reputational attacks, not just physical violence.
Background of the Case
- The Relationship: Catherine Honacher and Michael Clemmons Uhlhorn lived together in Hurdle Mills, NC, but never married. Honacher contributed about $305,000 toward their home purchase, while Uhlhorn put in $60,000. Title was in Honacher’s name, and there was no agreement about division if they split.
- The Breakup: After the relationship ended, Uhlhorn moved to Ohio in 2018.
- The Harassment: Honacher alleged that Uhlhorn launched a years-long campaign to pressure her financially and damage her reputation, including:
- Filing fraudulent liens against her NC properties.
- Reporting her to realtors, MLS services, and state agencies.
- Accusing her of fraud and disparaging her publicly.
- Sending threatening messages, vowing he would “never leave her alone.”
- Prior Incidents: She also described past aggression, including slamming a car door on her arm and throwing a chair.
In June 2023, the trial court issued a DVPO, finding his conduct caused fear of continued harassment and substantial emotional distress.
The Appeal
Uhlhorn challenged the DVPO, arguing:
- The court lacked personal jurisdiction because he lived in Ohio.
- The court lacked subject matter jurisdiction because Honacher was not truly a North Carolina resident.
- His communications had a legitimate purpose and could not be considered harassment.
The Court’s Analysis
1. Jurisdiction Was Proper
- Personal jurisdiction: The Court held Uhlhorn waived this defense by failing to raise it early. He initially admitted Honacher was a NC resident, and later contradictions did not undo that.
- Subject matter jurisdiction: Under N.C.G.S. § 50B-2(a), a petitioner “residing” in NC may seek a DVPO. Residency does not require full-time presence. Because Honacher owned multiple NC homes, spent time here regularly, and was targeted for harassment tied to her NC property, jurisdiction was proper.
2. Harassment Standard Met
The Court noted Uhlhorn’s actions—false liens, complaints, disparagement, and threats—fit the statutory definition of harassment: conduct that torments or terrorizes another and serves no legitimate purpose. While framed as “fraud reporting,” the evidence showed his intent was intimidation and control.
3. DVPO Affirmed
The Court upheld the DVPO, finding his conduct caused serious emotional distress—panic attacks, anxiety, sleeplessness—and was part of a continuing pattern of harassment.
Key Lessons from Honacher v. Uhlhorn
- DVPOs Cover More Than Physical Abuse
Harassment, intimidation, and reputational attacks can justify protective orders when they cause significant emotional harm. - Residency Is Broadly Defined
Owning property and maintaining ties to NC is enough to establish residency for DVPO jurisdiction. - Don’t Delay Jurisdiction Defenses
Personal jurisdiction challenges must be raised immediately—or they’re waived. - “Legitimate Purpose” Is Narrow
Courts see through attempts to disguise harassment as legitimate complaints. Repeated, targeted attacks are unlikely to qualify.
Conclusion
Honacher v. Uhlhorn reinforces that North Carolina domestic violence law protects against more than physical harm. Courts will act to stop harassment that undermines safety and peace of mind—especially when financial disputes escalate into intimidation.
At Adkins Law, PLLC, based in Huntersville, we represent clients in DVPO cases and related property disputes. Whether you’re seeking protection or defending against allegations, our team provides clear guidance and strong advocacy.
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