1. Does the preponderance of the evidence standard used for the issuance of a DVRO in California comply with the Fourteenth Amendment's guarantees of due process?

2. Does the vagueness of the language in California Family Code § 6320(c) instructing courts to issue DVROs for "conduct that, based on the totality of the circumstances, destroys the mental or emotional calm of the other party" violate constitutional due process? And if it does not, may non-violent non-threatening speech be used to support a protective order that deprives its subject of constitutional rights?

Does the preponderance of the evidence standard for Domestic Violence Restraining Orders in California violate due process under the Fourteenth Amendment, and can non-violent speech support such orders?