Supreme Court
Goldstein v. Sabatino
- Case number: 22-0678
- Legal category: Jurisdiction
- Subtype: Territorial Jurisdiction
- Set for oral argument: February 20, 2024
Case Summary
The primary issue in this case is whether a trial court must have territorial jurisdiction over an alleged offender’s conduct to issue a protective order under the Texas Code of Criminal Procedure.
Rachel Goldstein and James Sabatino dated while they both lived in Massachusetts. Three years after they stopped dating, Goldstein obtained a protective order in Massachusetts prohibiting Sabatino from contacting her. After Goldstein moved to Texas, Sabatino filed several small-claims suits against Goldstein, and the notices were forwarded to her in Texas.
Goldstein applied for a protective order in Texas under the Code of Criminal Procedure. Following a hearing, the trial court found there were reasonable grounds to believe that Goldstein was a victim of stalking and harassment. It issued a lifetime protective order prohibiting Sabatino from various acts. The court of appeals reversed and vacated the order, holding that the trial court lacked territorial jurisdiction over Sabatino’s alleged harassment because the conduct all occurred in Massachusetts.
Goldstein petitioned the Supreme Court for review, arguing that territorial jurisdiction is solely a criminal-law concept and does not apply to protective orders, which are civil matters. She contends the court of appeals erred in vacating the order because the trial court had both subject-matter jurisdiction and personal jurisdiction over Sabatino.
The Court granted Goldstein’s petition for review.
Case summaries are created by the Court's staff attorneys and law clerks and do not constitute the Court’s official descriptions or statements. Readers are encouraged to review the Court’s official opinions for specifics regarding each case. Links to the full case documents are included above.