The appellant challenged a protection from abuse (PFA) order that compelled him to avoid a particular temple on Sundays when his ex-wife worshiped there. He claimed that the PFA unlawfully impeded his free exercise of religion. The Superior Court disagreed and affirmed the PFA. The Court noted that the order would only violate the First Amendment if it placed a “substantial” burden on the appellant’s religious practice. But here, the order merely prohibited the appellant from attending a single temple for a short and defined period of time on Sundays when his ex-wife worshiped there. The Court held this was not a substantial burden.
