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Mikeson, Terek v. Mertyle Umbrington

2026-08-31

Summary

Holding. The Delaware Supreme Court affirmed the Family Court's dismissal of Mikeson's protection-from-abuse petition, finding no error or abuse of discretion in the court's rejection of his claims based on the February 2024 incident (which had already resulted in an expired PFA consent order) or his allegations of subsequent conduct that did not constitute abuse under state law.

Terek Mikeson appealed a Family Court decision dismissing his petition for a protection-from-abuse order against his former partner Mertyle Umbrington. Mikeson had previously obtained a temporary PFA consent order based on a February 2024 assault incident, but when he sought to extend it, a commissioner denied the extension. Rather than appealing that denial, Mikeson filed a new PFA petition based on the same February 2024 incident plus allegations of subsequent harassment and retaliation. The Family Court held a trial on the new petition and denied it, finding that the allegations about the February 2024 incident were duplicative of those underlying the expired consent order and that the subsequent conduct did not constitute abuse under state law.

On appeal, Mikeson raised several objections: that the court wrongly excluded a police report about the February 2024 incident, that he was denied a fair hearing when the court questioned the relevance of his cell phone video, and that Umbrington made false statements about his address. The Supreme Court found no error or abuse of discretion in the Family Court's rulings. The court explained that even if the police report had been admissible, it would not have changed the outcome because Mikeson had already received a PFA based on that same incident and should have appealed the denial of extension rather than filing a new petition based on identical facts.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether a new protection-from-abuse petition can be based on the same incident underlying an expired PFA consent order
  • Admissibility of police investigative reports as public records exceptions to hearsay
  • Whether questioning the relevance of evidence deprived a party of a fair tribunal
  • Proper procedure for challenging a commissioner's denial of a PFA extension

Procedural posture

Mikeson appealed a Family Court order dismissing his protection-from-abuse petition after a trial held on December 4, 2025.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

TEREK MIKESON,1 §

§ No. 37, 2026

Petitioner Below, §

Appellant, § Court Below—Family Court

§ of the State of Delaware

v. §

§ File No. CN24-02516

MERTYLE UMBRINGTON, § Petition No. 25-15900

§

Respondent Below, §

Appellee. §

Submitted: June 19, 2026

Decided: August 31, 2026

Before SEITZ, Chief Justice; LEGROW and GRIFFITHS, Justices.

ORDER

Upon consideration of the parties’ briefs, the appellant’s motions for

supervisory authority and modification of the case name, and the record on appeal,

it appears to the Court that:

(1) The petitioner below-appellant, Terek Mikeson, filed this appeal from

a Family Court order dismissing his petition for a protection-from-abuse (“PFA”)

order. We find no error or abuse of discretion in the Family Court’s decision and

therefore affirm.

1

The Court previously assigned pseudonyms to the parties under Supreme Court Rule 7(d).

(2) In April 2024, Mikeson filed a PFA petition against his former partner

Mertyle Umbrington. He alleged that Umbrington had physically assaulted him in

February. In May 2024, the Family Court entered the parties’ PFA consent order

against Umbrington. The expiration date of the order was May 16, 2025.

(3) On March 19, 2025, Mikeson moved to extend the PFA consent order

for two more years. He alleged that he suffered serious injuries when Umbrington

assaulted him in February 2024, Umbrington wrongly denied assaulting him, and he

feared running into Umbrington in Delaware. A Family Court commissioner

extended the PFA consent order until July 18, 2025 to allow for scheduling of a

hearing. After a hearing on July 16, 2025, the commissioner denied Mikeson’s

motion for an extension of the PFA consent order.

(4) Instead of seeking review of the commissioner’s ruling, Mikeson filed

a petition for a new PFA. Mikeson alleged that he suffered serious injuries in the

February 2024 incident and that Umbrington was engaging in a pattern of

harassment and retaliation against him. Umbrington then filed a petition for a PFA,

alleging that Mikeson was making false and defamatory statements about him

online. A commissioner dismissed both petitions. Mikeson sought review of the

commissioner’s decision. The Family Court found that Mikeson was deprived of his

procedural due process right to a trial on his petition and scheduled a trial for

December 4, 2025.

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(5) At the December 4, 2025 trial on his PFA petition, Mikeson testified

that Umbrington seriously injured him in February 2024 and that Umbrington’s

denial of this conduct in other forums was abusive. The Family Court denied

Mikeson’s petition. The court found that Mikeson’s allegations concerning the

February 2024 incident were duplicative of his allegations leading to the expired

PFA consent order and did not justify a new PFA. As to Mikeson’s contentions

concerning Umbrington’s conduct since the February 2024 incident, the court

concluded that none of that conduct constituted abuse under 10 Del. C. 1041(1).

(6) Mikeson filed a motion for reargument. Mikeson also filed a motion for

referral for criminal charges, alleging that Umbrington had provided a false address

and should be charged with perjury and other crimes. The Family Court denied both

motions. This appeal followed.

(7) The Court’s review of a Family Court decision includes a review of

both the law and the facts.2 Conclusions of law are reviewed de novo.3 Factual

findings will not be disturbed on appeal unless they are clearly erroneous.4

(8) On appeal, Mikeson argues that: (i) the Family Court erred by

excluding the police report concerning the February 2024 incident; (ii) the Family

2

Mundy v. Devon, 906 A.2d 750, 752 (Del. 2006).

3

Id.

4

Id.

3

Court deprived him of a fair tribunal by questioning the relevance of his cell phone

recording of the February 2024 incident; (iii) Umbrington submitted false addresses

to the Family Court and this Court; and (iv) there was cumulative error. Mikeson has

waived appellate review of claims that he raised below but does not argue on appeal.5

(9) The Family Court found that the police report concerning the February

2024 incident was inadmissible hearsay in the absence of the police officer who

prepared the report or a records custodian from the police department. Mikeson

argues that the Family Court erred because the report was admissible as a public

record under Rule 803(8) of the Delaware Rules of Evidence (“D.R.E.”). Rule

803(8) exempts qualifying public records from the hearsay rule. Rule 803(8)(A)

excludes investigative reports prepared by police from this exception to the hearsay

rule, but Mikeson contends that the police report was not an investigative report.

(10) Mikeson did not include a copy of the police report with his appendix

so we are unable to determine whether it is an investigative report or not. But even

if the report was admissible under Rule 803(8), the outcome of the proceeding would

not change. As the Family Court recognized, Mikeson had already obtained a PFA

consent order based on the February 2024 incident. A commissioner denied

Mikeson’s motion to extend that order. Mikeson could have sought review of the

5

Somerville v. State, 703 A.2d 629, 631 (Del. 1997); Murphy v. State, 632 A.2d 1150, 1152 (Del. 1993).

4

commissioner’s order, but did not do so. He could not then obtain a new PFA based

on the same incident underlying the expired PFA consent order.

(11) Contrary to Mikeson’s contentions, the Family Court did not deprive

him of a fair tribunal by questioning the relevance of evidence he offered concerning

the February 2024 incident with Umbrington. Mikeson asked the court to watch

video he recorded on his cell phone of the February 2024 incident that led to the

PFA consent order. The Family Court questioned whether the video was relevant,

but still viewed the video as Mikeson requested. The relevance of the video was in

fact questionable given that Mikeson had already obtained a PFA consent order

based on the February 2024 incident and had not sought review of the

commissioner’s order denying his motion for extension of that order. The Family

Court did not err in questioning the relevance of the video of the February 2024

incident.

(12) Mikeson next contends that Umbrington made false statements and

falsely certified his address in the Family Court. He has also moved for this Court to

require Umbrington to provide documentary evidence and a sworn statement

concerning his address because he allegedly provided a false address to this Court.

The Family Court denied Mikeson’s motion for referral for criminal charges, finding

that Umbrington’s allegedly false statements were not related to dismissal of the

PFA petition. We find no error in the Family Court’s denial of this motion. In light

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of our rulings above, Mikeson has not established cumulative error. Nor has he

demonstrated good cause for modification of the pseudonyms assigned in this case

or for requiring Umbrington to submit documentary evidence and a sworn statement

concerning his address.

NOW, THEREFORE, IT IS ORDERED that Mikeson’s motions are DENIED

and the judgment of the Family Court is AFFIRMED.

BY THE COURT:

/s/ N. Christopher Griffiths

Justice

6