DeHaven's request for a temporary protection order was denied because of his sexual orientation. The fear of such treatment reverberates through the gay community -- that their life choices will affect the protection they receive -- and keeps some from coming forward.

The Ohio Revised Code defines domestic violence as harm or attempted harm to a "family or household member." In a 1991 Franklin County Court of Appeals case, State v. Hadinger, the judges concluded that the intent of the law was to provide protection to people who are cohabiting, regardless of their gender, under the "person living as a spouse" section of the law.