The Arizona Court of Appeals recently addressed the question as to whether the issuance of an order of protection requires actual physical violence. In its recent decision in Michaelson v. Garr, the Arizona Court of Appeals stated that actual physical violence is not necessary for a court to issue an order of protection. Michaelson and Garr broke up in September, 2012. Michaelson received an order of protection in October, 2012. Garr later requested a hearing on the order of protection. At the hearing, Michaelson never claimed that Garr committed any acts of physical domestic violence. She testified that Garr was harassing her. On September 26, 2012, he sent her over 60 unwanted text messages, and on October 4, 2012, he…