Facts: Petitioner and Respondent attended the same university in 2024. Respondent repeatedly initiated unwanted contact with Petitioner, who sought help from the university. The university prohibited Respondent from contacting Petitioner.

After graduation, Respondent repeatedly attempted to contact Petitioner through social media, creating new accounts when she blocked him. On the day the university’s no-contact restriction expired in May 2025, he attempted to reach her through a friend. He later appeared at an unrelated indoor soccer game where Petitioner was competing. Petitioner experienced fear and emotional distress from the continuing attempts at contact.

The general sessions court granted Petitioner an order of protection. Respondent appealed to circuit court, arguing that his federal Title IX lawsuit against the university deprived Tennessee courts of jurisdiction. Petitioner testified about the conduct described in her petition, and Respondent did not challenge its factual basis. The circuit court found that Respondent committed the acts alleged and granted an order of protection based on stalking.

Respondent appealed.

On Appeal: The Court of Appeals affirmed the order of protection.

TCA § 36-3-601 et seq. authorizes Tennessee courts to issue orders of protection, including to stalking victims. Stalking requires a course of repeated or continuing unconsented contact rather than an isolated incident. A victim’s testimony alone may establish the underlying conduct, even under the higher criminal standard.

A federal lawsuit against a third party does not, without more, eliminate a state court’s authority to adjudicate a separate petition under Tennessee law.

The Court found no error in the trial court’s decision to grant an order of protection:

[Respondent] also argues that there was an insufficient basis for the circuit court to grant the order of protection. [Respondent] appears to mistakenly believe that because [Petitioner] was the only witness that there was no proof. On the contrary, however, even in a criminal trial with a higher standard of proof, an offense may be established by the testimony of a victim alone.

He also asserts that, although the statute requires multiple acts, there was no repeated contact. His insufficiency argument takes out of context one sentence in the petition that identified “[o]ne incident where Respondent has showed up where she was.” The petition as a whole was not factually based on a singular incident but instead detailed the history of [Respondent’s] continuous, multiple attempts to have unconsented-to contact with [Petitioner]. The trial court found that [Petitioner] gave testimony establishing all of “the things listed in the Petition.”

Because [Petitioner]’s testimony alone is sufficient to establish the basis for the order and because she testified to repeated and continuing unconsented contact, [Respondent] is not entitled to relief.

The Court affirmed the trial court’s decision.

K.O.’s Comment: A stalking case does not require a parade of corroborating witnesses. If the trial court finds the victim credible, the victim’s testimony alone may carry the burden of proof. Lawyers should still present messages, account records, screenshots, witnesses, and other corroboration when available, but the absence of those materials is not the same as an absence of proof. Respondents should address the testimony itself instead of assuming that one witness means no evidence.

Stalking is a course-of-conduct offense, so slicing the proof into isolated events can distort the analysis. Lawyers should present the timeline as a connected sequence and explain the continuity of purpose.

Source: Tuplin v. Delgadillo (Tennessee Court of Appeals, Middle Section, October 23, 2026).

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