Existing law establishes the Domestic Violence Prevention Act for the purpose of preventing acts of domestic violence, abuse, and sexual abuse and providing for a separation of the persons involved in the domestic violence for a period sufficient to enable those persons to seek a resolution of the causes of the violence. Existing law authorizes a court to issue an ex parte protective order enjoining a party from, among other things, disturbing the peace of the other party. Existing law provides that disturbing the peace of the other party refers to conduct that includes coercive control, as defined, which includes unreasonably engaging in specified actions, including isolating the other party from friends, relatives, or other sources of support. Existing law makes an intentional and knowing violation of a protective order punishable as a misdemeanor.

This bill would include forced marriage for purposes of the act. The bill would define forced marriage as a spousal relationship in which one or both parties do not or cannot consent and one or both parties are compelled, through force, fraud, coercion, duress, abuse of power, or coercive control, to enter, attempt to enter, or maintain, a marriage, regardless of whether the marriage is legally valid. If a protective order is sought to protect against a forced marriage, the bill would authorize all persons engaged in conduct to arrange, officiate, finance, or facilitate a forced marriage or attempted forced marriage to be included in one action as respondents. The bill would provide that coercive control, for purposes of the act, includes interfering with, threatening, or attempting to prevent a party or witness from participating in a court proceeding. The bill would provide that conduct undertaken to compel, attempt to compel, prepare for, or facilitate a forced marriage constitutes disturbing the peace of the other party, as specified. The bill would require the provisions of the act to be liberally construed. The bill would authorize a court to grant relief regardless of whether a marriage has occurred or whether a purported marriage would be legally valid in this state or any other jurisdiction. Because a violation of a protective order is punishable as a crime, by expanding the bases for the issuance of these orders, the bill would expand an existing crime, thereby imposing a state-mandated local program.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

Existing law establishes the Domestic Violence Prevention Act for the purpose of preventing acts of domestic violence, abuse, and sexual abuse and providing for a separation of the persons involved in the domestic violence for a period sufficient to enable those persons to seek a resolution of the causes of the violence. Existing law authorizes a court to issue an ex parte protective order enjoining a party from, among other things, disturbing the peace of the other party. Existing law provides that disturbing the peace of the other party refers to conduct that includes coercive control, as defined, which includes unreasonably engaging in specified actions, including isolating the other party from friends, relatives, or other sources of support. Existing law makes an intentional and knowing violation of a protective order punishable as a misdemeanor.

This bill would include forced marriage for purposes of the act. The bill would define forced marriage as a spousal relationship in which one or both parties do not or cannot consent and one or both parties are compelled, through force, fraud, coercion, duress, abuse of power, or coercive control, to enter, attempt to enter, or maintain, a marriage, regardless of whether the marriage is legally valid. If a protective order is sought to protect against a forced marriage, the bill would authorize all persons engaged in conduct to arrange, officiate, finance, or facilitate a forced marriage or attempted forced marriage to be included in one action as respondents. The bill would provide that coercive control, for purposes of the act, includes interfering with, threatening, or attempting to prevent a party or witness from participating in a court proceeding. The bill would provide that conduct undertaken to compel, attempt to compel, prepare for, or facilitate a forced marriage constitutes disturbing the peace of the other party, as specified. The bill would require the provisions of the act to be liberally construed. The bill would authorize a court to grant relief regardless of whether a marriage has occurred or whether a purported marriage would be legally valid in this state or any other jurisdiction. Because a violation of a protective order is punishable as a crime, by expanding the bases for the issuance of these orders, the bill would expand an existing crime, thereby imposing a state-mandated local program.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

Existing law establishes the Domestic Violence Prevention Act for the purpose of preventing acts of domestic violence, abuse, and sexual abuse and providing for a separation of the persons involved in the domestic violence for a period sufficient to enable those persons to seek a resolution of the causes of the violence. Existing law authorizes a court to issue an ex parte protective order enjoining a party from, among other things, disturbing the peace of the other party. Existing law provides that disturbing the peace of the other party refers to conduct that includes coercive control, as defined, which includes unreasonably engaging in specified actions, including isolating the other party from friends, relatives, or other sources of support. Existing law makes an intentional and knowing violation of a protective order punishable as a misdemeanor.

This bill would include forced marriage for purposes of the act. The bill would define forced marriage as a spousal relationship in which one or both parties do not or cannot consent and one or both parties are compelled, through force, fraud, coercion, duress, abuse of power, or coercive control, to enter, attempt to enter, or maintain, a marriage, regardless of whether the marriage is legally valid. If a protective order is sought to protect against a forced marriage, the bill would authorize all persons engaged in conduct to arrange, officiate, finance, or facilitate a forced marriage or attempted forced marriage to be included in one action as respondents. The bill would provide that coercive control, for purposes of the act, includes interfering with, threatening, or attempting to prevent a party or witness from participating in a court proceedings. proceeding. The bill would provide that conduct undertaken to compel, attempt to compel, prepare for, or facilitate a forced marriage constitutes disturbing the peace of the other party, as specified. The bill would authorize a court to issue a protective order upon reasonable proof of prior instances of forced marriage or a credible risk of a forced marriage occurring, as specified. The bill would require the provisions of the act to be liberally construed to prevent forced marriage and related coercive conduct. construed. The bill would authorize a court to grant relief regardless of whether a marriage has occurred or whether a purported marriage would be legally valid in this state or any other jurisdiction. Because a violation of a protective order is punishable as a crime, by expanding the bases for the issuance of these orders, the bill would expand an existing crime, thereby imposing a state-mandated local program.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

Existing law establishes the Domestic Violence Prevention Act for the purpose of preventing acts of domestic violence, abuse, and sexual abuse and providing for a separation of the persons involved in the domestic violence for a period sufficient to enable those persons to seek a resolution of the causes of the violence. Existing law authorizes a court to issue an ex parte protective order enjoining a party from, among other things, disturbing the peace of the other party. Existing law provides that disturbing the peace of the other party refers to conduct that includes coercive control, as defined, which includes unreasonably engaging in specified actions, including isolating the other party from friends, relatives, or other sources of support. Existing law makes an intentional and knowing violation of a protective order punishable as a misdemeanor.

This bill would include forced marriage for purposes of the act. The bill would define forced marriage as a spousal relationship in which one or both parties do not or cannot consent and one or both parties are compelled, through force, fraud, coercion, duress, abuse of power, or coercive control, to enter, attempt to enter, or maintain, a marriage, regardless of whether the marriage is legally valid. The bill would provide that coercive control, for purposes of the act, includes interfering with, threatening, or attempting to prevent a party or witness from participating in court proceedings. The bill would provide that conduct undertaken to compel, attempt to compel, prepare for, or facilitate a forced marriage constitutes disturbing the peace of the other party, as specified. The bill would authorize a court to issue a protective order upon reasonable proof of prior instances of forced marriage or a credible risk of a forced marriage occurring, as specified. The bill would require the provisions of the act to be liberally construed to prevent forced marriage and related coercive conduct. Because a violation of a protective order is punishable as a crime, by expanding the bases for the issuance of these orders, the bill would expand an existing crime, thereby imposing a state-mandated local program.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

CONCURRENCE IN SENATE AMENDMENTS

CSA1 Bill Id:AB 2534

Author:(Kalra)

As Amended Ver:June 11, 2026

Majority vote

SUMMARY

Incorporates forced marriage as grounds for petitioning the court for a domestic violence restraining order.

Major Provisions

1. Amends the definition of "domestic violence" to include abuse perpetrated against a party subjected to a forced marriage or an attempted forced marriage.
2. Defines "forced marriage" to mean a spousal relationship in which one or both parties do not or cannot consent and one or both parties are compelled, through force, fraud, coercion, duress, abuse of power, or coercive control, to enter, attempt to enter, or maintain a marriage, regardless of whether the marriage is legally valid. Specifies that if an order is sought to protect against a forced marriage, every person who engaged in conduct to arrange, officiate, finance, or facilitate a forced marriage or attempted forced marriage may be included in one action as respondents.
3. Authorizes an order to be issued under the Domestic Violence Prevention Act (DVPA) upon reasonable proof of prior instances of forced marriage or a credible risk of forced marriage occurring.
4. Authorizes the court to grant relief regardless of whether a marriage has occurred or whether a purported marriage would be legally valid in this state or any other jurisdiction.
5. Expands the existing definition of "coercive control" for purposes of determining whether a party has been "disturbing the peace of the other party" to include interfering with, threatening, or attempting to prevent a party or witness from participating in court proceedings;
6. Expands the definition of "disturbing the peace of the other party" to also include conduct undertaken to compel, attempt to compel, prepare for, or facilitate a forced marriage.
7. Authorizes the court, in cases involving forced marriage or a credible risk thereof, to issue an order otherwise authorized under the DVPA, including specified examples.

Senate Amendments

Make clarifying changes to streamline the bill's provisions and facilitate implementation.

COMMENTS

Forced marriage, where one or both parties is compelled to enter into a marriage without consent, is an issue of global concern particularly impacting women and young girls from lower-income families. According to the United Nations Office on Drugs and Crime, children from poor families or who are in unstable situations, including those with uncertain immigration status, are more likely to face pressure to enter into an unwanted marriage. Once in such relationships, victims often endure additional emotional trauma and abuse, physical violence, and financial abuse. (Forced marriage and human trafficking: What you need to know, United Nations Office on Drugs and Crime available at: https://www.unodc.org/unodc/en/frontpage/2025/December/forced-marriage-and-human-trafficking_-what-you-need-to-know.html.) Forced marriages, which can be coordinated by other family members or non-family community members, may also involve isolating the victim or victims from their support networks. According to data provided by the proponents of the measure, victims of forced marriages are often taken across state and international borders, limiting the ability of California and United States authorities to intervene. Unfortunately, it seems California's existing laws may have a blind spot with regard to the subject of forced marriages, leaving these survivors out in the cold. In an effort to bolster protections for parties to forced marriages, this bill expands the DVPA to capture the unique circumstances created by forced marriages and clarify a path for survivors to obtain domestic violence restraining orders against any potential party to the coercion.

Definitions. As currently enacted, the DVPA defines "domestic violence" as abuse perpetrated against certain people including: a spouse or former spouse; a cohabitant or former cohabitant; a person in a current or former dating or engagement relationship; a person with whom someone has had a child; a child; or any other person of blood-relationship within the second degree. This bill amends the definition of "domestic violence" to include abuse perpetrated against a party subjected to a forced marriage or an attempted forced marriage. To further incorporate forced marriages under the scope of the DVPA, this bill also defines "forced marriage" as a spousal relationship in which at least one person does not or cannot consent and are compelled to enter into the marriage, regardless of whether the marriage itself is legally valid. This bill also specifies that if an order is sought to protect against a forced marriage, every person who engaged in conduct to arrange, officiate, finance, or facilitate a forced marriage or attempted forced marriage may be included in one action as respondents. This language reflects one of the unique aspects of a forced marriage in that it does not necessarily only involve the parties to be married, but also often includes larger communities and parties outside of the intended marriage.

According to the Author

AB 2534 is a critical piece of legislation that will extend domestic violence protections for women and girls being forced into a marriage or survivors of forced marriages. Victims of forced marriage often experience abuse, isolation, financial control, surveillance, and immigration threats from the perpetrator and extended family. In these cases, the perpetrator does not act alone, and coercion is often reinforced by family members or community members.

While forced marriages are a crime under existing law, many victims find themselves in dangerous situations without protective measures. The ability to file a restraining order will empower young girls and women to take steps to protect themselves with confidence.

AB 2534 will ensure that those being forced into a marriage, or survivors of a forced marriage, can get a restraining order against their perpetrator and others aiding in this process. By adding forced marriage to the Domestic Violence Prevention Act, these women and young girls will be able to file a Domestic Violence Restraining Order to ensure their safety and protection from those forcing them into a nonconsensual marriage.

Arguments in Support

This bill is sponsored by the Family Violence Law Center, Tahirih Justice Center, and Choose Your Path Foundation. It enjoys additional support from a number of domestic violence prevention organizations, family law-focused organizations, Planned Parenthood Affiliates of California, and the Women's Foundation California. The Family Violence Appellate Project has submitted a position of support if amended. In support of the bill, Family Violence Law Center writes:

This critical legislation addresses a dangerous gap in California's protection of survivors by explicitly recognizing forced marriage as a form of abuse under the Domestic Violence Prevention Act (DVPA).

[…]

Forced marriage is a serious violation of human rights that often involves physical violence, sexual assault, and confinement. Without the specific protections provided by AB 2534, many survivors are left without a clear legal pathway to prevent these harms before they occur. The need for this bill is underscored by several alarming data points:

1. A Pervasive but Hidden Crisis: Between 2009 and 2011, the Tahirih Justice Center– a sponsor of this bill– received reports of nearly 3,000 cases of forced marriage or the risk of forced marriage in the United States.1 Many of these cases involved minors and young adults who were unable to access traditional legal remedies.
2. The Threat of International Abduction: Forced marriage often involves "vacationing" survivors to other countries where they have fewer legal rights. According to the U.S. Department of State, once a survivor is taken across international borders, the ability of the U.S. government to intervene is severely limited. AB 2534 provides the preemptive, emergency authority needed to order the surrender of travel documents, stopping this abduction before it begins.
3. Coercive Control and Overlapping Abuse: Research indicates that forced marriage is rarely an isolated incident; it is almost always accompanied by coercive control, including financial abuse, physical threats, and reproductive coercion. Under current California law, the DVPA does not explicitly list forced marriage as a basis for a Domestic Violence Restraining Order (DVRO), making it difficult for courts to provide comprehensive relief.
4. Safety Upon Separation: Data shows that separation is the most dangerous time for victims of domestic abuse. For those attempting to flee a forced marriage, this risk is heightened by the involvement of extended family or community actors who may aid in the coercion.

AB 2534 provides survivors with a robust "shield" by allowing the court to prohibit third parties from facilitating a marriage and ensuring that a survivor is not removed from school or essential services as a means of punishment or control. California must join other leading states in providing clear, actionable legal protections for those at risk of being forced into a marriage against their will. We urge your support for this life-saving measure.

Arguments in Opposition

None on file

FISCAL COMMENTS

According to the Senate Appropriations Committee, minor to modest costs to the Judicial Council to modify and adopt new forms to incorporate forced marriage into the DVRO process.

Minor to modest costs to trial courts for additional DVRO filings and hearings. Many potential petitioners may already qualify for a DVRO under existing law, so it is unclear how many filings would be entirely new. DVRO hearings operate on tight statutory timeframes, and additional filings may result in some delays for other civil cases. While the courts are not funded on a workload basis, an increase in workload could result in delayed court services and would put pressure on the General Fund to fund additional staff and resources. The FY 2026–27 Budget appropriated $70 million General Fund for this purpose (Trial Court Trust Fund, General Fund).

VOTES:

ASM JUDICIARY: 12-0-0

YES: Kalra, Macedo, Bauer-Kahan, Bryan, Connolly, Dixon, Harabedian, Pacheco, Papan, Sanchez, Stefani, Zbur

ASM APPROPRIATIONS: 13-0-2

YES: Wicks, Hoover, Arambula, Caloza, Dixon, Fong, Mark González, Krell, Pacheco, Pellerin, Solache, Ta, Tangipa

ABS, ABST OR NV: Calderon, Muratsuchi

ASSEMBLY FLOOR: 69-0-11

YES: Addis, Aguiar-Curry, Ahrens, Alanis, Alvarez, Ávila Farías, Bains, Bauer-Kahan, Bennett, Berman, Boerner, Bryan, Calderon, Caloza, Carrillo, Castillo, Connolly, Davies, DeMaio, Dixon, Elhawary, Ellis, Fong, Gabriel, Gallagher, Garcia, Gipson, Jeff Gonzalez, Mark González, Hadwick, Haney, Harabedian, Irwin, Jackson, Johnson, Kalra, Krell, Lackey, Lee, Lowenthal, Macedo, McKinnor, Muratsuchi, Nguyen, Ortega, Pacheco, Papan, Patel, Patterson, Pellerin, Quirk-Silva, Ramos, Ransom, Michelle Rodriguez, Rogers, Blanca Rubio, Sanchez, Schiavo, Schultz, Sharp-Collins, Solache, Soria, Stefani, Ta, Tangipa, Ward, Wilson, Zbur, Rivas

ABS, ABST OR NV: Arambula, Bonta, Chen, Flora, Hart, Hoover, Petrie-Norris, Celeste Rodriguez, Valencia, Wallis, Wicks

SENATE FLOOR: 40-0-0

YES: Allen, Alvarado-Gil, Archuleta, Arreguín, Ashby, Becker, Blakespear, Cabaldon, Caballero, Cervantes, Choi, Cortese, Dahle, Durazo, Gonzalez, Grayson, Grove, Hurtado, Jones, Laird, Limón, McGuire, McNerney, Menjivar, Niello, Ochoa Bogh, Padilla, Pérez, Reyes, Richardson, Rubio, Seyarto, Smallwood-Cuevas, Stern, Strickland, Umberg, Valladares, Wahab, Weber Pierson, Wiener

UPDATED

VERSION: June 11, 2026

CONSULTANT: Manuela Boucher-de la CAdena / JUD. / (916) 319-2334 FN: 0003898

CONCURRENCE IN SENATE AMENDMENTS

CSA1 Bill Id:AB 2534

Author:(Kalra)

As Amended Ver:June 11, 2026

Majority vote

SUMMARY

Incorporates forced marriage as grounds for petitioning the court for a domestic violence restraining order.

Major Provisions

1. Amends the definition of "domestic violence" to include abuse perpetrated against a party subjected to a forced marriage or an attempted forced marriage.
2. Defines "forced marriage" to mean a spousal relationship in which one or both parties do not or cannot consent and one or both parties are compelled, through force, fraud, coercion, duress, abuse of power, or coercive control, to enter, attempt to enter, or maintain a marriage, regardless of whether the marriage is legally valid. Specifies that if an order is sought to protect against a forced marriage, every person who engaged in conduct to arrange, officiate, finance, or facilitate a forced marriage or attempted forced marriage may be included in one action as respondents.
3. Authorizes an order to be issued under the Domestic Violence Prevention Act (DVPA) upon reasonable proof of prior instances of forced marriage or a credible risk of forced marriage occurring.
4. Authorizes the court to grant relief regardless of whether a marriage has occurred or whether a purported marriage would be legally valid in this state or any other jurisdiction.
5. Expands the existing definition of "coercive control" for purposes of determining whether a party has been "disturbing the peace of the other party" to include interfering with, threatening, or attempting to prevent a party or witness from participating in court proceedings;
6. Expands the definition of "disturbing the peace of the other party" to also include conduct undertaken to compel, attempt to compel, prepare for, or facilitate a forced marriage.
7. Authorizes the court, in cases involving forced marriage or a credible risk thereof, to issue an order otherwise authorized under the DVPA, including specified examples.

Senate Amendments

Make clarifying changes to streamline the bill's provisions and facilitate implementation.

COMMENTS

Forced marriage, where one or both parties is compelled to enter into a marriage without consent, is an issue of global concern particularly impacting women and young girls from lower-income families. According to the United Nations Office on Drugs and Crime, children from poor families or who are in unstable situations, including those with uncertain immigration status, are more likely to face pressure to enter into an unwanted marriage. Once in such relationships, victims often endure additional emotional trauma and abuse, physical violence, and financial abuse. (Forced marriage and human trafficking: What you need to know, United Nations Office on Drugs and Crime available at: https://www.unodc.org/unodc/en/frontpage/2025/December/forced-marriage-and-human-trafficking_-what-you-need-to-know.html.) Forced marriages, which can be coordinated by other family members or non-family community members, may also involve isolating the victim or victims from their support networks. According to data provided by the proponents of the measure, victims of forced marriages are often taken across state and international borders, limiting the ability of California and United States authorities to intervene. Unfortunately, it seems California's existing laws may have a blind spot with regard to the subject of forced marriages, leaving these survivors out in the cold. In an effort to bolster protections for parties to forced marriages, this bill expands the DVPA to capture the unique circumstances created by forced marriages and clarify a path for survivors to obtain domestic violence restraining orders against any potential party to the coercion.

Definitions. As currently enacted, the DVPA defines "domestic violence" as abuse perpetrated against certain people including: a spouse or former spouse; a cohabitant or former cohabitant; a person in a current or former dating or engagement relationship; a person with whom someone has had a child; a child; or any other person of blood-relationship within the second degree. This bill amends the definition of "domestic violence" to include abuse perpetrated against a party subjected to a forced marriage or an attempted forced marriage. To further incorporate forced marriages under the scope of the DVPA, this bill also defines "forced marriage" as a spousal relationship in which at least one person does not or cannot consent and are compelled to enter into the marriage, regardless of whether the marriage itself is legally valid. This bill also specifies that if an order is sought to protect against a forced marriage, every person who engaged in conduct to arrange, officiate, finance, or facilitate a forced marriage or attempted forced marriage may be included in one action as respondents. This language reflects one of the unique aspects of a forced marriage in that it does not necessarily only involve the parties to be married, but also often includes larger communities and parties outside of the intended marriage.

According to the Author

AB 2534 is a critical piece of legislation that will extend domestic violence protections for women and girls being forced into a marriage or survivors of forced marriages. Victims of forced marriage often experience abuse, isolation, financial control, surveillance, and immigration threats from the perpetrator and extended family. In these cases, the perpetrator does not act alone, and coercion is often reinforced by family members or community members.

While forced marriages are a crime under existing law, many victims find themselves in dangerous situations without protective measures. The ability to file a restraining order will empower young girls and women to take steps to protect themselves with confidence.

AB 2534 will ensure that those being forced into a marriage, or survivors of a forced marriage, can get a restraining order against their perpetrator and others aiding in this process. By adding forced marriage to the Domestic Violence Prevention Act, these women and young girls will be able to file a Domestic Violence Restraining Order to ensure their safety and protection from those forcing them into a nonconsensual marriage.

Arguments in Support

This bill is sponsored by the Family Violence Law Center, Tahirih Justice Center, and Choose Your Path Foundation. It enjoys additional support from a number of domestic violence prevention organizations, family law-focused organizations, Planned Parenthood Affiliates of California, and the Women's Foundation California. The Family Violence Appellate Project has submitted a position of support if amended. In support of the bill, Family Violence Law Center writes:

This critical legislation addresses a dangerous gap in California's protection of survivors by explicitly recognizing forced marriage as a form of abuse under the Domestic Violence Prevention Act (DVPA).

[…]

Forced marriage is a serious violation of human rights that often involves physical violence, sexual assault, and confinement. Without the specific protections provided by AB 2534, many survivors are left without a clear legal pathway to prevent these harms before they occur. The need for this bill is underscored by several alarming data points:

1. A Pervasive but Hidden Crisis: Between 2009 and 2011, the Tahirih Justice Center– a sponsor of this bill– received reports of nearly 3,000 cases of forced marriage or the risk of forced marriage in the United States.1 Many of these cases involved minors and young adults who were unable to access traditional legal remedies.
2. The Threat of International Abduction: Forced marriage often involves "vacationing" survivors to other countries where they have fewer legal rights. According to the U.S. Department of State, once a survivor is taken across international borders, the ability of the U.S. government to intervene is severely limited. AB 2534 provides the preemptive, emergency authority needed to order the surrender of travel documents, stopping this abduction before it begins.
3. Coercive Control and Overlapping Abuse: Research indicates that forced marriage is rarely an isolated incident; it is almost always accompanied by coercive control, including financial abuse, physical threats, and reproductive coercion. Under current California law, the DVPA does not explicitly list forced marriage as a basis for a Domestic Violence Restraining Order (DVRO), making it difficult for courts to provide comprehensive relief.
4. Safety Upon Separation: Data shows that separation is the most dangerous time for victims of domestic abuse. For those attempting to flee a forced marriage, this risk is heightened by the involvement of extended family or community actors who may aid in the coercion.

AB 2534 provides survivors with a robust "shield" by allowing the court to prohibit third parties from facilitating a marriage and ensuring that a survivor is not removed from school or essential services as a means of punishment or control. California must join other leading states in providing clear, actionable legal protections for those at risk of being forced into a marriage against their will. We urge your support for this life-saving measure.

Arguments in Opposition

None on file

FISCAL COMMENTS

According to the Senate Appropriations Committee, minor to modest costs to the Judicial Council to modify and adopt new forms to incorporate forced marriage into the DVRO process.

Minor to modest costs to trial courts for additional DVRO filings and hearings. Many potential petitioners may already qualify for a DVRO under existing law, so it is unclear how many filings would be entirely new. DVRO hearings operate on tight statutory timeframes, and additional filings may result in some delays for other civil cases. While the courts are not funded on a workload basis, an increase in workload could result in delayed court services and would put pressure on the General Fund to fund additional staff and resources. The FY 2026–27 Budget appropriated $70 million General Fund for this purpose (Trial Court Trust Fund, General Fund).

VOTES:

ASM JUDICIARY: 12-0-0

YES: Kalra, Macedo, Bauer-Kahan, Bryan, Connolly, Dixon, Harabedian, Pacheco, Papan, Sanchez, Stefani, Zbur

ASM APPROPRIATIONS: 13-0-2

YES: Wicks, Hoover, Arambula, Caloza, Dixon, Fong, Mark González, Krell, Pacheco, Pellerin, Solache, Ta, Tangipa

ABS, ABST OR NV: Calderon, Muratsuchi

ASSEMBLY FLOOR: 69-0-11

YES: Addis, Aguiar-Curry, Ahrens, Alanis, Alvarez, Ávila Farías, Bains, Bauer-Kahan, Bennett, Berman, Boerner, Bryan, Calderon, Caloza, Carrillo, Castillo, Connolly, Davies, DeMaio, Dixon, Elhawary, Ellis, Fong, Gabriel, Gallagher, Garcia, Gipson, Jeff Gonzalez, Mark González, Hadwick, Haney, Harabedian, Irwin, Jackson, Johnson, Kalra, Krell, Lackey, Lee, Lowenthal, Macedo, McKinnor, Muratsuchi, Nguyen, Ortega, Pacheco, Papan, Patel, Patterson, Pellerin, Quirk-Silva, Ramos, Ransom, Michelle Rodriguez, Rogers, Blanca Rubio, Sanchez, Schiavo, Schultz, Sharp-Collins, Solache, Soria, Stefani, Ta, Tangipa, Ward, Wilson, Zbur, Rivas

ABS, ABST OR NV: Arambula, Bonta, Chen, Flora, Hart, Hoover, Petrie-Norris, Celeste Rodriguez, Valencia, Wallis, Wicks

UPDATED

VERSION: June 11, 2026

CONSULTANT: Manuela Boucher-de la CAdena / JUD. / (916) 319-2334 FN: 0003898

 THIRD READING  

Bill No: AB 2534

Author: Kalra (D), et al.

Amended: 6/11/26 in Senate

Vote: 21

SENATE JUDICIARY COMMITTEE: 13-0, 6/23/26

AYES: Umberg, Niello, Allen, Ashby, Caballero, Durazo, Laird, Reyes, Stern, Valladares, Wahab, Weber Pierson, Wiener

SENATE APPROPRIATIONS COMMITTEE: 6-0, 8/13/26

AYES: Cervantes, Seyarto, Cabaldon, Dahle, Grayson, Richardson

NO VOTE RECORDED: Wahab

ASSEMBLY FLOOR: 69-0, 5/7/26 - See last page for vote

SUBJECT: Domestic Violence Prevention Act: forced marriage

SOURCE: Family Violence Law Center
Tahirih Justice Center

DIGEST:

This bill adds “forced marriage,” as defined, to the list of abusive conduct constituting domestic violence under the Domestic Violence Prevention Act (DVPA) and clarifies that a person may obtain a DVPA order to protect against a forced marriage.

ANALYSIS:

Existing law:

1. Establishes the DVPA, which sets forth procedural and substantive requirements for the issuance of a temporary restraining order or a protective order to, among other things, enjoin specific acts of abuse or prohibit the abuser from coming within a specified distance of the abused person. (Family (Fam.) Code, §§ 6200 et seq.)
2. Defines “domestic violence” as abuse perpetrated against a spouse or former spouse; a cohabitant or former cohabitant; a person with whom the respondent is having or has had a dating or engagement relationship; a person with whom the respondent has had a child, as specified; a child of a party or a child who is the subject of an action under the Uniform Parentage Act, as specified; or any other person related by consanguinity or affinity within the second degree. (Fam. Code, § 6211.)
3. Authorizes a court to issue an ex parte temporary restraining order (TRO) under the DVPA without a noticed hearing. (Fam. Code, §§ 6320-6327.)
4. Authorizes a court to issue DVPO under the DVPA after a noticed hearing at which the alleged abuser may appear. (Fam. Code, §§ 6340-6347.)
5. Provides that an order issued under 3) or 4) may enjoin a party from molesting, attacking, striking, stalking, threatening, sexually assaulting, battering, credibly impersonating, falsely impersonating, harassing, telephoning, destroying personal property, contacting, coming within a specified distance of, or disturbing the peace of the other party, and, at the discretion of the court, on a showing of good cause, of other named family or household members. (Fam. Code, § 6320(a).)
6. Provides that “disturbing the peace of the other party,” for purposes of 5), refers to conduct that, based on the totality of the circumstances, destroys the mental or emotional calms of the other party, which includes, but is not limited to, coercive control; “coercive control” is a pattern of behavior that in purpose or effect unreasonably interferes with a person’s free will or personal liberty. (Fam. Code, § 6320(c).)
7. Provides that examples of coercive control include, but are not limited to, unreasonably engaging in any of the following:
   1. Isolating the other party from friends, relatives, or other sources of support.
   2. Depriving the other party of basic necessities.
   3. Controlling, regulating, or monitoring the other party’s movements, communications, daily behavior, finances, economic resources, or access to services.
   4. Compelling the other party by force, threat of force, or intimidation, including threats based on actual or suspected immigration status, to engage in conduct from which the other party has a right to abstain, or to abstain from conduct in which the other party has a right to engage.
   5. Engaging in reproductive coercion, which consists of control over the reproductive autonomy of another through force, threat of force, or intimidation, and may include, but is not limited to, unreasonably pressuring the other party to become pregnant, deliberately interfering with contraception use or access to reproductive health information, or using coercive tactics to control, or attempt to control, pregnancy outcomes. (Fam. Code, § 6320(c)(1)-(5).)
8. Provides that a marriage is voidable and may be adjudged a nullity if specified conditions existed at the time of the marriage, including that the consent of either party was obtained by force, unless the party whose consent was obtained by force afterwards freely cohabitated with the other as their spouse. (Fam. Code, § 2210(e).)
9. Provides that a proceeding to obtain a judgment of nullity of marriage for a marriage in which consent was obtained by force must be brought:
   1. Until January 1, 2027, within four years after the marriage.
   2. Beginning January 1, 2027, within four years of the marriage, except that the court, upon a showing of good cause, may permit a party to proceed with the petition outside the expiration of the four-year statute of limitations. (Fam. Code, § 2211; AB 1134 (Bains, Ch. 633, Stats. 2025).)
10. Provides that it is a crime to compel another person, unlawfully, against their will, and by force, menace, or duress, to marry them or to marry another person, regardless of the age of the victim of the forced marriage at the time of the forced marriage. (Pen. Code, § 265.)

This bill:

1. Makes findings and declarations stating that forced marriage is a form of coercive control that falls within the protective purposes of the DVPA and the need for protections for victims of forced marriage under California law.
2. Adds, to the definition of “domestic violence” within the DVPA, abuse perpetrated against a party subjected to a forced marriage or an attempted forced marriage.
3. Defines “forced marriage” as a spousal relationship in which one or both parties do not or cannot consent and one or both parties are compelled, through force, fraud, coercion, duress, abuse of power, or coercive control, to enter, attempt to enter, or maintain a marriage, regardless of whether the marriage is legally valid; “forced marriage” constitutes abuse for purposes of the DVPA.
4. Provides that, if a DVPA order is sought to protect against a forced marriage, every person who engaged in conduct to arrange, officiate, finance, or facilitate the forced marriage or attempted force marriage may be included in one action as respondents.
5. Requires the DVPA to be liberally construed, and states that relief shall not be denied on the basis that the conduct is claimed to be customary, religious, cultural, or lawful in another jurisdiction, and that passage of time alone shall not bar relief.
6. Permits a court to grant a DVPA order regardless of whether a marriage has occurred or whether a purported marriage would be legally valid in this state or another jurisdiction.
7. Adds, to the list of examples of coercive control, interfering with, threatening, or attempting to prevent a party or witness from participating in court proceedings.
8. Provides that conduct taken to compel, attempt to compel, prepare for, or facilitate a forced marriage constitutes disturbing the peace of the other party; such conduct includes, but is not limited to:
   1. Threats, intimidation, harassment, or abuse targeted at a person in an attempt to secure a marriage without consent.
   2. Confiscating, withholding, or controlling passports, visas, identity documents, or travel documents.
   3. Isolation, surveillance, restriction of movement or communication, or financial control.
   4. Arranging, officiating, financing, or facilitating a forced marriage ceremony or related travel.
9. Provides that, in a DVPA case involving forced marriage or a credible risk of forced marriage, the court may issue an order otherwise authorized under the DVPA, including, but not limited to:
   1. An order prohibiting the arrangement, solemnization, or facilitation of a marriage involving the protected party without the party’s consent.
   2. An order requiring the surrender to the court or return of passports, visas, or other travel or identity documents necessary to prevent removal of the protected party.
   3. An order necessary to ensure that a person is not removed from school or prevented from attending school, a medical or mental health appointment, a meeting with a service provider or attorney, an extracurricular activity, or other conduct to which the protected party has a right to engage.
   4. An order necessary to prevent the transportation of a person outside the jurisdiction for purposes related to a forced marriage.

Comments

Existing law, the DVPA, seeks to prevent acts of domestic violence, abuse, and sexual abuse and to provide for a separation of persons involved in the domestic violence for a period sufficient to enable these persons to try to resolve the causes of the violence. Existing law thus enables a party to seek a restraining order or a protective order to enjoin specific acts of abuse, exclude a person from a dwelling, or enjoin other specified behavior. The DVPA allows a victim of domestic violence to obtain a short-term temporary restraining order (TRO) on an ex parte basis and a longer-term protective order after a noticed hearing (DVPO); these orders are generally sought in a single application that seeks the immediate issuance of a TRO and a hearing on the application for the protective order.

This bill clarifies that the DVPA extends to protect against a planned forced marriage and to protect victims of forced marriages that have already taken place. At a high level, forced marriage is already covered by the DVPA through prohibitions on violence, threats of violence, and coercive control, but this bill adds both clarity and guidance to the courts on the potential scope of a forced-marriage-related DVPA order.

FISCAL EFFECT: Appropriation: No Fiscal Com.: Yes Local: Yes

According to the Senate Appropriations Committee, the fiscal effect is as follows:

Minor to modest costs to the Judicial Council to modify and adopt new forms to incorporate forced marriage into the DVRO process.

Minor to modest costs to trial courts for additional DVRO filings and hearings. Many potential petitioners may already qualify for a DVRO under existing law, so it is unclear how many filings would be entirely new. DVRO hearings operate on tight statutory timeframes, and additional filings may result in some delays for other civil cases. While the courts are not funded on a workload basis, an increase in workload could result in delayed court services and would put pressure on the General Fund to fund additional staff and resources. The FY 2026–27 Budget appropriated $70 million General Fund for this purpose (Trial Court Trust Fund, General Fund).

SUPPORT: (Verified 8/13/26)

Family Violence Law Center (co-source)
Tahirih Justice Center (co-source)

California Asian Pacific American Bar Association

California Family Council
California Partnership to End Domestic Violence

Church State Council
County of Santa Clara
Family Violence Appellate Project

Healthy Alternatives to Violent Environments

Hilde B Foundation
Maitri Bay Area
Planned Parenthood Affiliates of California

Rainbow Services
Restraining Orders Without Borders
Sexual Assault Advocacy Network

The Adjacent Project
Valor US

Women’s Foundation California

Women’s Liberation Front

OPPOSITION: (Verified 8/13/26)

None received

ARGUMENTS IN SUPPORT: According to the Tahirih Justice Center:

Forced marriage is a serious violation of human rights that often involves physical violence, sexual assault, and confinement. Without the specific protections provided by AB 2534, many survivors are left without a clear legal pathway to prevent these harms before they occur or to escape a forced marriage after it has happened. The need for this bill is underscored by several alarming data points:

• A Pervasive but Hidden Crisis: Between 2009 and 2011, the Tahirih Justice Center– a sponsor of this bill– received reports of nearly 3,000 known or suspected cases of forced marriage in the United States.
• Many of these cases involved minors and young adults who were unable to access traditional legal remedies. Within this data were confirmed cases in California.
• The Threat of International Abduction: Forced marriage often involves “vacationing” survivors to other countries where they have fewer legal rights. According to the U.S. Department of State, once a survivor is taken across international borders and married, the ability of the U.S. government to intervene is severely limited. AB 2534 provides the preemptive, emergency authority needed to stop such an abduction before it begins.
• Coercive Control and Overlapping Abuse: Research indicates that forced marriage is rarely an isolated incident; it is almost always accompanied by coercive control, including financial abuse, physical threats, and reproductive coercion. Current California law does not explicitly list forced marriage as a basis for a Domestic Violence Restraining Order (DVRO), making it difficult for courts to provide comprehensive relief to these survivors.
• Safety Upon Separation: Data shows that separation is the most dangerous time for victims of domestic violence. For those attempting to flee a forced marriage, this risk is heightened by the involvement of extended family or community actors who may aid in the abuse and coercion and make it even harder to find a safe pathway out.

AB 2534 provides survivors with a robust “shield” by allowing the court to restrain every person involved in facilitating a forced marriage simultaneously to protect against these uniquely risky and harmful dynamics present in forced marriage cases.

ASSEMBLY FLOOR: 69-0, 5/7/26

AYES: Addis, Aguiar-Curry, Ahrens, Alanis, Alvarez, Ávila Farías, Bains, Bauer-Kahan, Bennett, Berman, Boerner, Bryan, Calderon, Caloza, Carrillo, Castillo, Connolly, Davies, DeMaio, Dixon, Elhawary, Ellis, Fong, Gabriel, Gallagher, Garcia, Gipson, Jeff Gonzalez, Mark González, Hadwick, Haney, Harabedian, Irwin, Jackson, Johnson, Kalra, Krell, Lackey, Lee, Lowenthal, Macedo, McKinnor, Muratsuchi, Nguyen, Ortega, Pacheco, Papan, Patel, Patterson, Pellerin, Quirk-Silva, Ramos, Ransom, Michelle Rodriguez, Rogers, Blanca Rubio, Sanchez, Schiavo, Schultz, Sharp-Collins, Solache, Soria, Stefani, Ta, Tangipa, Ward, Wilson, Zbur, Rivas

NO VOTE RECORDED: Arambula, Bonta, Chen, Flora, Hart, Hoover, Petrie-Norris, Celeste Rodriguez, Valencia, Wallis, Wicks

Prepared by: Allison Whitt Meredith / JUD. / (916) 651-4113

8/14/26 14:07:07

**** END ****

SENATE COMMITTEE ON

Senator Sabrina Cervantes, Chair

2025 - 2026 Regular Session

AB 2534 (Kalra) - Domestic Violence Prevention Act: forced marriage

Bill Summary:

AB 2534 adds forced marriage to the list of abusive conduct constituting domestic violence under the Domestic Violence Prevention Act (DVPA).

Fiscal Impact:

Minor to modest costs to the Judicial Council to modify and adopt new forms to incorporate forced marriage into the DVRO process.

Minor to modest costs to trial courts for additional DVRO filings and hearings. Many potential petitioners may already qualify for a DVRO under existing law, so it is unclear how many filings would be entirely new. DVRO hearings operate on tight statutory timeframes, and additional filings may result in some delays for other civil cases. While the courts are not funded on a workload basis, an increase in workload could result in delayed court services and would put pressure on the General Fund to fund additional staff and resources. The FY 2026-27 Budget appropriated $70 million General Fund for this purpose (Trial Court Trust Fund, General Fund).

Background:

The DVPA enables a party to seek a restraining order or a protective order to enjoin specific acts of abuse, exclude a person from a dwelling, or enjoin other specified behavior. The DVPA allows a victim of domestic violence to obtain a short-term temporary restraining order (TRO) and a longer-term protective order after a noticed hearing (DVPO). These orders are generally sought in a single application that seeks the immediate issuance of a TRO and a hearing on the application for the protective order.

Proposed Law:

Domestic violence is abuse perpetrated against any of the following persons:

a) A spouse or former spouse.

b) A cohabitant or former cohabitant.

c) A person with whom the respondent is having or has had a dating or engagement relationship.

d) A person with whom the respondent has had a child, where the presumption applies that the male parent is the father of the child of the female parent.

e) A child of a party or a child who is the subject of an action, where the presumption applies that the male parent is the father of the child to be protected.

f) Any other person related by consanguinity or affinity within the second degree.

This bill would add a party subjected to a forced marriage or an attempted forced marriage.

SENATE JUDICIARY COMMITTEE

Senator Thomas Umberg, Chair

2025-2026 Regular Session

Bill No: AB 2534 (Author:Kalra)

Version: June 11, 2026

Hearing Date: June 23, 2026

Fiscal: Yes

Urgency: No

Consultant: AWM

SUBJECT

Domestic Violence Prevention Act: forced marriage

DIGEST

This bill adds “forced marriage,” as defined, to the list of abusive conduct constituting domestic violence under the Domestic Violence Prevention Act (DVPA) and clarifies that a person may obtain a DVPA order to protect against a forced marriage.

EXECUTIVE SUMMARY

Existing law, the DVPA, seeks to prevent acts of domestic violence, abuse, and sexual abuse and to provide for a separation of persons involved in the domestic violence for a period sufficient to enable these persons to try to resolve the causes of the violence. Existing law thus enables a party to seek a restraining order or a protective order to enjoin specific acts of abuse, exclude a person from a dwelling, or enjoin other specified behavior. The DVPA allows a victim of domestic violence to obtain a short-term temporary restraining order (TRO) on an ex parte basis and a longer-term protective order after a noticed hearing (DVPO); these orders are generally sought in a single application that seeks the immediate issuance of a TRO and a hearing on the application for the protective order.

This bill clarifies that the DVPA extends to protect against a planned forced marriage and to protect victims of forced marriages that have already taken place. At a high level, forced marriage is already covered by the DVPA through prohibitions on violence, threats of violence, and coercive control, but this bill adds both clarity and guidance to the courts on the potential scope of a forced-marriage-related DVPA order. The author recently took amendments to address stakeholder concerns; the organizations that had expressed those concerns are now in support of the bill.

This bill is sponsored by the Family Violence Law Center and Tahirih Justice Center and is supported by the California Family Council, the California Partnership to End Domestic Violence, the County of Santa Clara, the Family Violence Appellate Project, Maitri Bay Area, Planned Parenthood Affiliates of California, Restraining Orders Without Borders, the Sexual Assault Advocacy Network , and Valor US. The Committee has not received timely opposition to this bill.

PROPOSED CHANGES TO THE LAW

Existing law:

1. Establishes the DVPA, which sets forth procedural and substantive requirements for the issuance of a temporary restraining order or a protective order to, among other things, enjoin specific acts of abuse or prohibit the abuser from coming within a specified distance of the abused person. (Fam. Code, §§ 6200 et seq.)
2. Defines “domestic violence” as abuse perpetrated against a spouse or former spouse; a cohabitant or former cohabitant; a person with whom the respondent is having or has had a dating or engagement relationship; a person with whom the respondent has had a child, as specified; a child of a party or a child who is the subject of an action under the Uniform Parentage Act, as specified; or any other person related by consanguinity or affinity within the second degree. (Fam. Code, § 6211.)
3. Authorizes a court to issue an ex parte temporary restraining order (TRO) under the DVPA without a noticed hearing. (Fam. Code, §§ 6320-6327.)
4. Authorizes a court to issue DVPO under the DVPA after a noticed hearing at which the alleged abuser may appear. (Fam. Code, §§ 6340-6347.)
5. Provides that an order issued under 3) or 4) may enjoin a party from molesting, attacking, striking, stalking, threatening, sexually assaulting, battering, credibly impersonating, falsely impersonating, harassing, telephoning, destroying personal property, contacting, coming within a specified distance of, or disturbing the peace of the other party, and, at the discretion of the court, on a showing of good cause, of other named family or household members. (Fam. Code, § 6320(a).)
6. Provides that “disturbing the peace of the other party,” for purposes of 5), refers to conduct that, based on the totality of the circumstances, destroys the mental or emotional calms of the other party.
   1. This conduct may be committed directly or indirectly, including through the use of a third party.
   2. This conduct may be committed through any method or through any means including, but not limited to, telephone, online accounts, text messages, internet-connected devices, or other electronic technologies.
   3. This conduct includes, but is not limited to, coercive control, which is a pattern of behavior that in purpose or effect unreasonably interferes with a person’s free will or personal liberty. (Fam. Code, § 6320(c).)
7. Provides that examples of coercive control include, but are not limited to, unreasonably engaging in any of the following:
   1. Isolating the other party from friends, relatives, or other sources of support.
   2. Depriving the other party of basic necessities.
   3. Controlling, regulating, or monitoring the other party’s movements, communications, daily behavior, finances, economic resources, or access to services.
   4. Compelling the other party by force, threat of force, or intimidation, including threats based on actual or suspected immigration status, to engage in conduct from which the other party has a right to abstain, or to abstain from conduct in which the other party has a right to engage.
   5. Engaging in reproductive coercion, which consists of control over the reproductive autonomy of another through force, threat of force, or intimidation, and may include, but is not limited to, unreasonably pressuring the other party to become pregnant, deliberately interfering with contraception use or access to reproductive health information, or using coercive tactics to control, or attempt to control, pregnancy outcomes. (Fam. Code, § 6320(c)(1)-(5).)
8. Provides that a marriage is voidable and may be adjudged a nullity if specified conditions existed at the time of the marriage, including that the consent of either party was obtained by force, unless the party whose consent was obtained by force afterwards freely cohabitated with the other as their spouse. (Fam. Code, § 2210(e).)
9. Provides that a proceeding to obtain a judgment of nullity of marriage for a marriage in which consent was obtained by force must be brought:
   1. Until January 1, 2027, within four years after the marriage.
   2. Beginning January 1, 2027, within four years of the marriage, except that the court, upon a showing of good cause, may permit a party to proceed with the petition outside the expiration of the four-year statute of limitations. (Fam. Code, § 2211; AB 1134 (Bains, Ch. 633, Stats. 2025).)
10. Provides that it is a crime to compel another person, unlawfully, against their will, and by force, menace, or duress, to marry them or to marry another person, regardless of the age of the victim of the forced marriage at the time of the forced marriage. (Pen. Code, § 265.)

This bill:

1. Makes the following findings and declarations:
   1. Forced marriage is a form of abuse and coercive control that falls within the protective purposes of the DVPA; this bill clarifies that courts may issue restraining orders to prevent, enjoin, and remedy forced marriage using existing DVPA procedures and penalties.
   2. Forced marriage, in all its forms, is a pervasive issue in this state and a violation of fundamental human rights.
   3. Anyone, regardless of race, ethnicity, color, sex, gender identity or expression, sexual orientation, education, socioeconomic status, marital status, relationship to the perpetrator, immigration or citizenship status, language proficiency, veteran or military status, or disability, may be a victim of forced marriage.
   4. Forced marriage harms not only victims but also their families, communities, and society at large.
   5. Victims of forced marriage deserve full protection and relief under California law.
   6. The purposes of this measure are to prevent acts of forced marriage and related coercive conduct and to remedy their effects on victims and communities through timely and effective civil protection; this measure is intended to protect individuals from being forced into marriage or from attempts, threats, or preparations to compel marriage, and to provide relief to those seeking to escape or recover from that coercion.
2. Adds, to the definition of “domestic violence” within the DVPA, abuse perpetrated against a party subjected to a forced marriage or an attempted forced marriage.
3. Defines “forced marriage” as a spousal relationship in which one or both parties do not or cannot consent and one or both parties are compelled, through force, fraud, coercion, duress, abuse of power, or coercive control, to enter, attempt to enter, or maintain a marriage, regardless of whether the marriage is legally valid; “forced marriage” constitutes abuse for purposes of the DVPA.
4. Provides that, if a DVPA order is sought to protect against a forced marriage, every person who engaged in conduct to arrange, officiate, finance, or facilitate the forced marriage or attempted force marriage may be included in one action as respondents.
5. Requires the DVPA to be liberally construed, and states that relief shall not be denied on the basis that the conduct is claimed to be customary, religious, cultural, or lawful in another jurisdiction, and that passage of time alone shall not bar relief.
6. Permits a court to grant a DVPA order regardless of whether a marriage has occurred or whether a purported marriage would be legally valid in this state or another jurisdiction.
7. Adds, to the list of examples of coercive control, interfering with, threatening, or attempting to prevent a party or witness from participating in court proceedings.
8. Provides that conduct taken to compel, attempt to compel, prepare for, or facilitate a forced marriage constitutes disturbing the peace of the other party; such conduct includes, but is not limited to:
   1. Threats, intimidation, harassment, or abuse targeted at a person in an attempt to secure a marriage without consent.
   2. Confiscating, withholding, or controlling passports, visas, identity documents, or travel documents.
   3. Isolation, surveillance, restriction of movement or communication, or financial control.
   4. Arranging, officiating, financing, or facilitating a forced marriage ceremony or related travel.
9. Provides that, in a DVPA case involving forced marriage or a credible risk of forced marriage, the court may issue an order otherwise authorized under the DVPA, including, but not limited to:
   1. An order prohibiting the arrangement, solemnization, or facilitation of a marriage involving the protected party without the party’s consent.
   2. An order requiring the surrender to the court or return of passports, visas, or other travel or identity documents necessary to prevent removal of the protected party.
   3. An order necessary to ensure that a person is not removed from school or prevented from attending school, a medical or mental health appointment, a meeting with a service provider or attorney, an extracurricular activity, or other conduct to which the protected party has a right to engage.
   4. An order necessary to prevent the transportation of a person outside the jurisdiction for purposes related to a forced marriage.

COMMENTS

1. Author’s comment

According to the author:

AB 2534 is a critical piece of legislation that will extend domestic violence protections for individuals being forced into a marriage or survivors of forced marriages. Victims of forced marriage often experience abuse, isolation, financial control, surveillance, and immigration threats from the perpetrator and extended family. In these cases, the perpetrator does not act alone, and coercion is often reinforced by family members or community members.

While forced marriages are a crime under existing law, many victims find themselves in dangerous situations without protective measures. By giving the ability to file a restraining order against their perpetrator and others aiding in this process, AB 2534 will empower survivors to take steps that can better ensure their safety and protect them from those forcing them into a nonconsensual marriage.

2. Background on the DVPA

The DVPA seeks to prevent acts of domestic violence, abuse, and sexual abuse, and to provide for a separation of persons involved in domestic violence for a period sufficient to enable them to seek a resolution. The DVPA’s “protective purpose is broad both in its stated intent and its breadth of persons protected” and courts are required to construe it broadly in order to accomplish the statute’s purpose.^[1]

The DVPA allows a victim of domestic violence to obtain a short-term TRO on an ex parte basis and a DVPO after a noticed hearing;^[2] these orders are generally sought in a single application that seeks the immediate issuance of a TRO and a hearing on the application for the DVPO. A TRO or a DVPO can enjoin a range of conduct, including attacking, threatening, harassing, telephoning, contacting, and coming within a specified distance of the protected person.^[3] Both a TRO and a DVPO can be issued solely on the basis of the affidavit or testimony presented by the petitioner.^[4] A TRO generally lasts for 21 days, by which point the court must hold a noticed hearing on the issuance of a DVPO; however, the TRO may be extended if there is good cause for continuing the noticed hearing.^[5] If the court grants the application for a DVPO, the DVPO can last for up to five years and can be extended by the court so long as the risk of abuse remains.^[6]

The DVPA defines “abuse” broadly, covering physical harms, harm to property, and emotional harm arising from behavior such as stalking, harassing, and disturbing the peace.^[7] In 2020, the Legislature enacted SB 1141 (Rubio, Ch. 248, Stats. 2020), which codified caselaw holding that “disturbing the peace” includes “coercive control.”^[8] As explained by Dr. Evan Stark, a leading expert on coercive control:

Coercive control entails a malevolent course of conduct that subordinates women to an alien will by violating their physical integrity (domestic violence), denying them respect and autonomy (intimidation), depriving them of social connection (isolation) and appropriating or denying them access to the resources required for personhood and citizenship (control).^[9]

In 2021, the Legislature enacted SB 374 (Min, Ch. 135, Stats. 2021), which added “reproductive coercion” to the list of conduct that can constitute coercive control. “Reproductive coercion” is a prevalent form of abuse through which the abuser exerts “control over the reproductive autonomy of another through force, threat of force, or intimidation.”^[10]

3. The problem of forced marriage in California

A legal marriage in California requires the consent of two persons capable of giving consent; the issuance of a license; and the solemnization of the marriage by a person authorized to do so.^[11] A solemnized marriage in which one or both parties’ consent was obtained by fraud or force, or in which one or both parties was a minor who did not receive express approval from the court, is voidable and can be declared a nullity by the court.^[12] Forcing a person into a marriage against their will, through force, menace, or duress, is also a crime.^[13]

Despite these laws, forced marriage is still a problem in California and around the world:

Forced marriages often include elements of familial pressures, manipulation of religion, and/or cultural pressures. Familial, cultural or religious pressure are often used to manipulate victims of forced marriage, resulting in guilt or shame that limits their ability to speak up, report their experience, or seek help. Particularly in Western countries, the question of whether a marriage is forced has become muddled, where girls facing pressure to marry the father of their child due to fear of a child being born out of wedlock is seen simply as allowing the union to start on a strong foundation.^[14]

Millions of minors are forced into marriages every year across the world; “[f]orced marriage of minors exacerbates the human rights offense [of forced marriage] as it adds on statutory rape, early child bearing, prevents a child from completing secondary education, and sets a child on the path to life-long poverty and victimization.”^[15] And in some communities, girls are taught that they have no agency to decide whether, and whom, to marry, and face ostracism and poverty if they refuse their parents’ chosen husband; though the actual marriage might not take place until she is legally of age, her “consent” is often the product of a combination of coercive control, violence or threats of violence, and a feeling that she has no other options.^[16]

Californians can also find themselves forced into marriages abroad, in countries where there are fewer protections against forced marriage. “It is all too common for American citizens to return to their family's country of origin under the pretext of visiting family only to be held against their will until they agree to marry someone their family chose.”^[17] California is also home to persons who were forced into marriages abroad, or in other states, before moving to California.^[18] California’s out-of-state marriage law recognizes marriages that are valid under the laws of the jurisdiction where the marriage was solemnized,^[19] so a person forced into a marriage in a country where forced marriage is illegal would have recourse under California law. The onus is, however, still on the victim to reach out for help—California does not preemptively investigate the validity of its residents’ marriages.

4. This bill clarifies that the DVPA’s protections extend to forced marriage

As noted by the author and sponsors, perpetrators of forced marriage are typically the victim’s family members and/or the putative spouse themselves (though sometimes both parties to the marriage are forced into it), and therefore clearly fall within the categories of persons who can commit domestic violence for purposes of the DVPA.^[20] Similarly, forced marriage generally involves violence, the threat of violence, and coercive control, all of which are already covered by the DVPA.^[21] A court could, therefore, presumably issue a DVPA order on the basis of forced marriage, or an attempted forced marriage, under existing law.

That said, there are elements of forced marriage that make it dissimilar to what might be characterized as “traditional” domestic violence types. For example, the DVPA does not provide a straightforward remedy for a victim of a multi-party campaign of coercive control, which could make a court reluctant to grant an order that seeks protection against a victim’s parents and putative future spouse.

To cure any potential ambiguity, this bill expressly includes forced marriage within the ambit of abusive conduct covered by the DVPA. The bill also provides courts with guidance on the potential scope of DVPA orders arising from an attempted forced marriage, or a forced marriage that has already been solemnized. Under the bill, the court can make a broad range of orders to protect against a planned or solemnized forced marriage, including an order to prohibit a marriage from going forward; an order for the surrender of the victim’s travel documents; or an order directed towards all of the individuals involved in the planned or solemnized forced marriage.

Given the range of forced marriage experiences, the bill casts a wide net. “Forced marriage” includes marriages that are conducted through the state’s license system as well as “marriages” that are solemnized without state involvement, such as a “religious-only” marriage officiated by a faith leader in the victim’s community. “Forced marriage” also includes a marriage that is, or is intended to be, conducted in another jurisdiction, including another country. To be clear, a DVPA order to protect a forced marriage victim who was married in another country would not invalidate the marriage—the victim would still have to go through a separate process to void the marriage—so there is no concern that this provision interferes with full faith and credit requirements. The protective order would, however, keep the victim safe from their abusers, thereby giving them the space they need to begin the nullification process and take whatever additional steps they need to begin to heal.

The author recently took amendments to address stakeholder concerns; the entities who had expressed those concerns are now in support of the bill.

5. Arguments in support

According to the Tahiri Justice Center:

Forced marriage is a serious violation of human rights that often involves physical violence, sexual assault, and confinement. Without the specific protections provided by AB 2534, many survivors are left without a clear legal pathway to prevent these harms before they occur or to escape a forced marriage after it has happened. The need for this bill is underscored by several alarming data points:

• A Pervasive but Hidden Crisis: Between 2009 and 2011, the Tahirih Justice Center– a sponsor of this bill– received reports of nearly 3,000 known or suspected cases of forced marriage in the United States.
• Many of these cases involved minors and young adults who were unable to access traditional legal remedies. Within this data were confirmed cases in California.
• The Threat of International Abduction: Forced marriage often involves "vacationing" survivors to other countries where they have fewer legal rights. According to the U.S. Department of State, once a survivor is taken across international borders and married, the ability of the U.S. government to intervene is severely limited. AB 2534 provides the preemptive, emergency authority needed to stop such an abduction before it begins.
• Coercive Control and Overlapping Abuse: Research indicates that forced marriage is rarely an isolated incident; it is almost always accompanied by coercive control, including financial abuse, physical threats, and reproductive coercion. Current California law does not explicitly list forced marriage as a basis for a Domestic Violence Restraining Order (DVRO), making it difficult for courts to provide comprehensive relief to these survivors.
• Safety Upon Separation: Data shows that separation is the most dangerous time for victims of domestic violence. For those attempting to flee a forced marriage, this risk is heightened by the involvement of extended family or community actors who may aid in the abuse and coercion and make it even harder to find a safe pathway out.
• AB 2534 provides survivors with a robust "shield" by allowing the court to restrain every person involved in facilitating a forced marriage simultaneously to protect against these uniquely risky and harmful dynamics present in forced marriage cases.

SUPPORT

Family Violence Law Center (co-sponsor)
Tahirih Justice Center (co-sponsor)

California Family Council
California Partnership to End Domestic Violence
County of Santa Clara
Family Violence Appellate Project
Maitri Bay Area
Planned Parenthood Affiliates of California
Restraining Orders Without Borders
Sexual Assault Advocacy Network
Valor US

OPPOSITION

None received

RELATED LEGISLATION

Pending legislation: None known.

Prior legislation:

AB 1134 (Bains, Ch. 633, Stats. 2025) updated the crime of coerced marriage and authorized, beginning January 1, 2027, a court to grant permission, upon a showing of good cause, for a party to proceed with a petition for nullity of marriage that is filed beyond the relevant filing period if the party’s consent to the marriage was obtained by force.

SB 374 (Min, Ch. 135, Stats. 2021) added “reproductive coercion” to the list of conduct that constitutes coercive control under the DVPA. SB 374 is discussed further in Part 2 of this analysis.

SB 1141 (Rubio, Ch. 248, Stats. 2020) codified caselaw recognizing that “disturbing the peace of another party” within the DVPA includes coercive control, as defined. SB 1141 is discussed further in Part 2 of this analysis.

PRIOR VOTES

Assembly Floor (Ayes 69, Noes 0)

Assembly Appropriations Committee (Ayes 13, Noes 0)

Assembly Judiciary Committee (Ayes 12, Noes 0)

**************

1. Caldwell v. Coppola (1990) 219 Cal.App.3d 859, 863; In re Marriage of Nadkarni (2009) 173 Cal.App.4th 1483, 1498. ↑

2. Fam. Code, §§ 6320, 6340. ↑

3. Id., §§ 6320, 6340. ↑

4. Id., § 6300(a). ↑

5. Id., §§ 242, 245. ↑

6. Id., § 6345. ↑

7. Id., § 6320(a). ↑

8. See Sen. Com. on Judiciary, Analysis of Sen. Bill No. 1141 (2019-2020 Reg. Sess.) as amended May 6, 2020, p. 5. ↑

9. Tucker, Domestic Violence as a Factor in Child Custody Determinations: Considering Coercive Control (May 2022) 90 Fordham L. Rev. 2673, 2676 (internal quotation marks omitted). ↑

10. Fam. Code, § 6320(c)(5); e.g., Saravi, Addressing Abusers’ Attack on Women’s Right to Reproductive Autonomy: Birth Control Sabotage (Apr. 2020) 23 Rich. Pub. Int. L. Rev. 91, 94. ↑

11. Fam. Code, § 300. ↑

12. Id., §§ 2210, 2211. Beginning in 2027, parties whose consent was obtained by force will have additional time in which to bring a petition for nullity of marriage, upon a showing of good cause. (See AB 1134 (Bains, Ch. 633, Stats. 2025).) ↑

13. Pen. Code, § 265. ↑

14. Birga, Khan, & Owens, Hidden Costs of Forced Marriage and Its Impact on Women and Girls Globally (2024) Family Violence Law Center, p. 7, available at https://fvlc.org/wp-content/uploads/2024/10/FVLC-Report_10.1.pdf. All links in this analysis are current as of June 18, 2026. ↑

15. Id. at p. 9. ↑

16. Valencia, ‘Trapped’: The American women and girls forced into marriage (Dec. 24, 2020) Al Jazeera, https://www.aljazeera.com/features/2020/12/24/america-women-and-girls-forced-into-marriage. ↑

17. Id. at p. 8. ↑

18. E.g., id. at p. 9. ↑

19. Fam. Code, § 308. ↑

20. Id., § 6211. ↑

21. Id., § 6320. ↑

ASSEMBLY THIRD READING

ATR Bill Id:AB 2534

Author:(Kalra)

As Introduced Ver:February 20, 2026

Majority vote

SUMMARY

Incorporates forced marriage as grounds for petitioning the court for a domestic violence restraining order.

Major Provisions

1. Amends the definition of "domestic violence" to include abuse perpetrated against a party to a forced marriage or an attempted forced marriage.
2. Defines "forced marriage" to mean a spousal relationship in which one or both parties do not or cannot consent and one or both parties are compelled, through force, fraud, coercion, duress, abuse of power, or coercive control, to enter, attempt to enter, or maintain a marriage, regardless of whether the marriage is legally valid.
3. Authorizes an order to be issued under the Domestic Violence Prevention Act (DVPA) upon reasonable proof of prior instances of forced marriage or a credible risk of forced marriage occurring.
4. Authorizes the court to grant relief regardless of whether a marriage has occurred or whether a purported marriage would be legally valid in this state or any other jurisdiction.
5. Expands the existing definition of "coercive control" for purposes of determining whether a party has been "disturbing the peace of the other party" to include interfering with, threatening, or attempting to prevent a party or witness from participating in court proceedings;
6. Expands the definition of "disturbing the peace of the other party" to also include conduct undertaken to compel, attempt to compel, prepare for, or facilitate a forced marriage. Provides examples that include but are not limited to any of the following:
   1. Threats, intimidation, harassment, or abuse targeted at a person in an attempt to secure a marriage without consent;
   2. Confiscating, withholding, or controlling passports, visas, identity documents, or travel documents;
   3. Isolation, surveillance, restriction of movement or communication, or financial control;
   4. Arranging, officiating, financing, or facilitating a marriage ceremony or related travel with knowledge that the marriage is being forced.
7. Authorizes the court, in cases involving forced marriage or a credible risk thereof, to issue any order otherwise authorized under the DVPA. Including, but not limited to orders specific to circumstances involving forced marriages.

COMMENTS

Forced marriage, where one or both parties is compelled to enter into a marriage without consent, is an issue of global concern particularly impacting women and young girls from lower-income families. According to the United Nations Office on Drugs and Crime, children from poor families or who are in unstable situations, including those with uncertain immigration status, are more likely to face pressure to enter into an unwanted marriage. Once in such relationships, victims often endure additional emotional trauma and abuse, physical violence, and financial abuse. (Forced marriage and human trafficking: What you need to know, United Nations Office on Drugs and Crime available at: https://www.unodc.org/unodc/en/frontpage/2025/December/forced-marriage-and-human-trafficking_-what-you-need-to-know.html.) Forced marriages, which can be coordinated by other family members or non-family community members, may also involve isolating the victim or victims from their support networks. According to data provided by the proponents of the measure, victims of forced marriages are often taken across state and international borders, limiting the ability of California and United States authorities to intervene. Unfortunately, it seems California’s existing laws may have a blind spot with regard to the subject of forced marriages, leaving these survivors out in the cold. In an effort to bolster protections for parties to forced marriages, this bill expands the DVPA to capture the unique circumstances created by forced marriages and clarify a path for survivors to obtain domestic violence restraining orders against any potential party to the coercion.

Definitions. As currently enacted, the DVPA defines "domestic violence" as abuse perpetrated against certain people including: a spouse or former spouse; a cohabitant or former cohabitant; a person in a current or former dating or engagement relationship; a person with whom someone has had a child; a child; or any other person of blood-relationship within the second degree. This bill amends the definition of “domestic violence” to include abuse perpetrated against a party to a forced marriage or an attempted forced marriage. To further incorporate forced marriages under the scope of the DVPA, this bill also defines "forced marriage" as a spousal relationship in which at least one person does not or cannot consent and are compelled to enter into the marriage, regardless of whether the marriage itself is legally valid.

Definition of "coercive control" and "disturbing the peace." Family Code Sections 6320 – 6327 provide guidelines and procedures for a court to issue an ex parte order. Section 6340 then allows a court to issue an order after a hearing on any of the same grounds authorized in the provisions guiding ex parte orders. (Family Code Section 6340.) Under Section 6320, a court may issue an ex parte order prohibiting the respondent from "disturbing the peace" of the petitioner. "Disturbing the peace" is further defined as "conduct, based on the totality of the circumstances, destroys the mental or emotional calm of the other party," and further specified to include "coercive control, which is a pattern of behavior that in purpose or effect unreasonably interferes with a person's free will and personal liberty." (Family Code Section 6320(c).) The statute then proceeds to give examples of coercive control, many of which may very well apply to situations involving forced marriage. However, survivors of forced marriages report that their experiences often fall outside the existing examples. Acknowledging this bill is proposing to expand the DVPA in a novel way and that more examples may therefore be helpful in the implementation of the changes, this provision would be modified to incorporate "interfering with, threatening, or attempting to prevent a party or witness from participating in court proceedings" as an example of "coercive control". Similarly, this bill expands this section to specify that conduct that seeks to “compel, attempt to compel, prepare for, or facilitate a forced marriage" constitutes disturbing the peace of the petitioning party, and provides a number of examples.

Expanding the types of proof of abuse that may justify a domestic violence restraining order (DVRO). Existing law authorizes a court to issue an order to restrain a person based on an affidavit or testimony that shows, to the satisfaction of the court, reasonable proof of a past act or acts of abuse. (Family Code Section 6300(a).) Family Code Section 6203 defines "abuse" as intentionally or recklessly causing or attempting to cause bodily injury; sexual assault; placing a person in reasonable apprehension of imminent serious bodily injury to that person or another; or engaging in any behavior that has been or could be enjoined in an ex parte order. This bill amends Family Code Section 6300 to allow a court to issue an order upon reasonable proof of prior instances of forced marriage or a credible risk of forced marriage occurring, regardless of whether a marriage actually occurred or would be legally valid in California.

Expanding the types of orders a judge may issue after a hearing on the petition. Finally, this bill proposes to expand the types of orders a judge can issue in a DVRO after a full hearing on the petition to reflect actions that may be appropriate to protect a party to a forced marriage. Reflecting experiences that victims of forced marriages commonly endure, this bill proposes to include the following as types of orders that a judge may issue in a DVRO: orders prohibiting the arrangement, solemnization, or facilitation of any marriage involving the protected party; orders requiring the surrender of passports or other forms of ID; orders necessary to ensure that a person is not removed from school or prevented from attending school, medical or mental health appointments, meetings with service providers or attorneys, or extracurricular activities; orders necessary to prevent transportation of a person outside of the court's jurisdiction for reasons related to the forced marriage. The bill also authorizes a court to issue “orders restraining third parties who knowingly aid or abet the conduct restricted by the DVRO, to the extent permitted by law." This language reflects one of the unique aspects of a forced marriage in that it does not necessarily only involve the parties to be married, but also often includes larger communities and parties outside of the intended marriage.

According to the Author

AB 2534 is a critical piece of legislation that will extend domestic violence protections for women and girls being forced into a marriage or survivors of forced marriages. Victims of forced marriage often experience abuse, isolation, financial control, surveillance, and immigration threats from the perpetrator and extended family. In these cases, the perpetrator does not act alone, and coercion is often reinforced by family members or community members.

While forced marriages are a crime under existing law, many victims find themselves in dangerous situations without protective measures. The ability to file a restraining order will empower young girls and women to take steps to protect themselves with confidence.

AB 2534 will ensure that those being forced into a marriage, or survivors of a forced marriage, can get a restraining order against their perpetrator and others aiding in this process. By adding forced marriage to the Domestic Violence Prevention Act, these women and young girls will be able to file a Domestic Violence Restraining Order to ensure their safety and protection from those forcing them into a nonconsensual marriage.

Arguments in Support

This bill is sponsored by the Family Violence Law Center, Tahirih Justice Center, and Choose Your Path Foundation. It enjoys additional support from a number of domestic violence prevention organizations, family law-focused organizations, Planned Parenthood Affiliates of California, and the Women’s Foundation California. The Family Violence Appellate Project has submitted a position of support if amended. In support of the bill, Family Violence Law Center writes:

This critical legislation addresses a dangerous gap in California’s protection of survivors by explicitly recognizing forced marriage as a form of abuse under the Domestic Violence Prevention Act (DVPA).

[…]

Forced marriage is a serious violation of human rights that often involves physical violence, sexual assault, and confinement. Without the specific protections provided by AB 2534, many survivors are left without a clear legal pathway to prevent these harms before they occur. The need for this bill is underscored by several alarming data points:

1. A Pervasive but Hidden Crisis: Between 2009 and 2011, the Tahirih Justice Center– a sponsor of this bill– received reports of nearly 3,000 cases of forced marriage or the risk of forced marriage in the United States.1 Many of these cases involved minors and young adults who were unable to access traditional legal remedies.
2. The Threat of International Abduction: Forced marriage often involves "vacationing" survivors to other countries where they have fewer legal rights. According to the U.S. Department of State, once a survivor is taken across international borders, the ability of the U.S. government to intervene is severely limited. AB 2534 provides the preemptive, emergency authority needed to order the surrender of travel documents, stopping this abduction before it begins.
3. Coercive Control and Overlapping Abuse: Research indicates that forced marriage is rarely an isolated incident; it is almost always accompanied by coercive control, including financial abuse, physical threats, and reproductive coercion. Under current California law, the DVPA does not explicitly list forced marriage as a basis for a Domestic Violence Restraining Order (DVRO), making it difficult for courts to provide comprehensive relief.
4. Safety Upon Separation: Data shows that separation is the most dangerous time for victims of domestic abuse. For those attempting to flee a forced marriage, this risk is heightened by the involvement of extended family or community actors who may aid in the coercion.

AB 2534 provides survivors with a robust "shield" by allowing the court to prohibit third parties from facilitating a marriage and ensuring that a survivor is not removed from school or essential services as a means of punishment or control. California must join other leading states in providing clear, actionable legal protections for those at risk of being forced into a marriage against their will. We urge your support for this life-saving measure.

Arguments in Opposition

None on file

FISCAL COMMENTS

According to the Assembly Appropriations Committee:

1. Minor and absorbable costs to the Judicial Council for modifying and adopting new forms to incorporate forced marriage into the DVRO process. The Judicial Council requests a one-year delayed implementation to make these changes effectively.
2. Unknown but likely minor costs to trial courts (Trial Court Trust Fund) for additional DVRO filings and hearings. According to the Judicial Council, many potential petitioners may already qualify for a DVRO under existing law, so it is unclear how many filings would be entirely new. The Judicial Council notes that DVRO hearings operate on tight statutory timeframes, and additional filings may result in some delays for other civil cases.

VOTES

ASM JUDICIARY: 12-0-0

YES: Kalra, Macedo, Bauer-Kahan, Bryan, Connolly, Dixon, Harabedian, Pacheco, Papan, Sanchez, Stefani, Zbur

ASM APPROPRIATIONS: 13-0-2

YES: Wicks, Hoover, Arambula, Caloza, Dixon, Fong, Mark González, Krell, Pacheco, Pellerin, Solache, Ta, Tangipa

ABS, ABST OR NV: Calderon, Muratsuchi

UPDATED

VERSION: February 20, 2026

CONSULTANT: Manuela Boucher / JUD. / (916) 319-2334 FN: 0002400

Date of Hearing: April 22, 2026

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Buffy Wicks, Chair

ABPCA Bill Id:AB 2534

Author:(Kalra) – As Introduced Ver:February 20, 2026

Urgency: No State Mandated Local Program: Yes Reimbursable: No

SUMMARY:

This bill incorporates forced marriage as grounds for petitioning the court for a domestic violence restraining order (DVRO) under the Domestic Violence Prevention Act (DVPA).

FISCAL EFFECT:

1. Minor and absorbable costs to the Judicial Council for modifying and adopting new forms to incorporate forced marriage into the DVRO process. The Judicial Council requests a one-year delayed implementation to make these changes effectively.
2. Unknown but likely minor costs to trial courts (Trial Court Trust Fund) for additional DVRO filings and hearings. According to the Judicial Council, many potential petitioners may already qualify for a DVRO under existing law, so it is unclear how many filings would be entirely new. The Judicial Council notes that DVRO hearings operate on tight statutory timeframes, and additional filings may result in some delays for other civil cases.

COMMENTS:

1. Purpose. According to the author, victims of forced marriage often experience abuse, isolation, financial control, surveillance, and immigration threats from the perpetrator and extended family. While forced marriages are a crime under existing law, many victims lack access to protective measures because they may not qualify for a DVRO under the current statutory framework. This bill ensures that parties to a forced or attempted forced marriage can obtain a DVRO against their perpetrators and others aiding in the coercion.
2. Background. The DVPA allows people in qualifying relationships to seek a restraining order against another person to protect against abusive behavior. Existing law defines “domestic violence” as abuse against a spouse, cohabitant, dating partner, person with whom the respondent has a child, or a person related by blood within the second degree. Forced marriages pose a complication because the coercion may be coordinated by community members or extended family who do not fall within these existing relationship categories. Additionally, Penal Code Section 265 criminalizes forcing someone to marry, but only captures completed, legally valid marriages — it does not provide protection against attempted or extrajudicial forced marriages. This bill addresses these gaps by creating an explicit pathway for forced marriage victims to obtain DVROs.
3. Support and Opposition. The Judicial Council raises a significant concern regarding the bill’s authorization for courts to issue orders restraining “third parties who knowingly aid or abet” enjoined conduct. The Judicial Council notes that any person subject to a restraining order must receive notice and an opportunity to be heard, and the current “third parties” language makes effective implementation difficult. The Judicial Council recommends that anyone restrained must be named as a party to the case rather than referenced as a third party in an order directed at someone else, and suggests the provision be amended to authorize “orders restraining a party from knowingly aiding or abetting conduct enjoined under this division.” The policy committee analysis and the Family Violence Appellate Project raise similar due process concerns.

Analysis Prepared by: Shiran Zohar / APPR. / (916) 319-2081

Date of Hearing: March 24, 2026

ASSEMBLY COMMITTEE ON JUDICIARY

Ash Kalra, Chair

ABPCA Bill Id:AB 2534

Author:(Kalra) – As Introduced Ver:February 20, 2026

SUBJECT: Domestic Violence Prevention Act: forced marriage

KEY ISSUE: SHOULD THE DOMESTIC VIOLENCE PREVENTION ACT BE AMENDED TO ALLOW A PARTY TO A COMPLETED OR FORCED MARRIAGE TO OBTAIN A DOMESTIC VIOLENCE RESTRAINING ORDER?

SYNOPSIS

Forced marriage, where one or both parties is compelled to enter into a marriage without consent, is an issue of global concern particularly impacting women and young girls from lower-income families. Once in a forced marriage, parties often experience additional emotional and physical abuse, and may be isolated from their support networks. These circumstances can make it exceedingly difficult for victims of a forced marriage to escape. While existing law criminalizes the act of compelling or forcing someone into a marriage and provides an opportunity for certain people to obtain a domestic violence restraining order, there appears to be a lack of legal recourse for victims of forced marriages. In particular, it appears that parties to a forced marriage may not qualify for a DVRO in many circumstances. This bill seeks to address this abandoned middle-ground by clearly establishing that a party to a completed or attempted forced marriage may petition the court for a domestic violence restraining order.

This bill is sponsored by the Family Violence Law Center, Choose Your Path, and Tahirih Justice Center. It enjoys support from Building Futures, Family Reunification Equity and Empowerment (F.R.E.E.), Gender Justice LA, Love Never Fails, Maitri Bay Area, Messaging for Success, Planned Parenthood Affiliates of California, Strong Hearted Native Women’s Coalition, Inc., and the Women’s Foundation California. The Family Violence Appellate Project has submitted a position of support if amended. Their requests are discussed in the body of this analysis. There is no formal opposition on file.

SUMMARY: Incorporates forced marriage as grounds for petitioning the court for a domestic violence restraining order. Specifically, this bill:

1. Makes the following findings and declarations:
   1. Forced marriage is a form of abuse and coercive control that falls within the protective purposes of the Domestic Violence Prevention Act (DVPA). This act clarifies that courts may issue restraining orders to prevent, enjoin, and remedy forced marriage using existing DVPA procedures and penalties;
   2. Forced marriage, in all its forms, is a pervasive issue in this state and a violation of fundamental human rights;
   3. Anyone, regardless of race, ethnicity, color, sex, gender identity or expression, sexual orientation, education, socioeconomic status, marital status, relationship to the perpetrator, immigration or citizenship status, language proficiency, veteran or military status, or disability, may be a victim of forced marriage;
   4. Forced marriage harms not only victims but also their families, communities, and society at large;
   5. Victims of forced marriage deserve full protection and relief under California law;
   6. The purposes of this measure are to prevent acts of forced marriage and to remedy their effects on victims and communities through timely and effective civil protection. This measure is intended to protect individuals from being forced into marriage or from attempts, threats, or preparations to compel marriage, and to provide relief to those seeking to escape or recover from that coercion.
2. Amends the definition of “domestic violence” to include abuse perpetrated against a party to a forced marriage or an attempted forced marriage.
3. Defines “forced marriage” to mean a spousal relationship in which one or both parties do not or cannot consent and one or both parties are compelled, through force, fraud, coercion, duress, abuse of power, or coercive control, to enter, attempt to enter, or maintain a marriage, regardless of whether the marriage is legally valid.
4. Instructs that the DVPA shall be liberally construed to prevent forced marriage and related coercive conduct. Prohibits relief from being denied on the basis that the conduct is claimed to be customary, religious, cultural, or lawful in another jurisdiction. Prohibits passage of time alone from barring relief.
5. Authorizes an order to be issued under the DVPA upon reasonable proof of prior instances of forced marriage or a credible risk of forced marriage occurring.
6. Authorizes the court to grant relief regardless of whether a marriage has occurred or whether a purported marriage would be legally valid in this state or any other jurisdiction.
7. Expands the existing definition of “coercive control” for purposes of determining whether a party has been “disturbing the peace of the other party” to include interfering with, threatening, or attempting to prevent a party or witness from participating in court proceedings;
8. Expands the definition of “disturbing the peace of the other party” to also include conduct undertaken to compel, attempt to compel, prepare for, or facilitate a forced marriage. Provides examples that include but are not limited to any of the following:
   1. Threats, intimidation, harassment, or abuse targeted at a person in an attempt to secure a marriage without consent;
   2. Confiscating, withholding, or controlling passports, visas, identity documents, or travel documents;
   3. Isolation, surveillance, restriction of movement or communication, or financial control;
   4. Arranging, officiating, financing, or facilitating a marriage ceremony or related travel with knowledge that the marriage is being forced.
9. Authorizes the court, in cases involving forced marriage or a credible risk thereof, to issue any order otherwise authorized under the DVPA. Including, but not limited to:
   1. Orders prohibiting the arrangement, solemnization, or facilitation of any marriage involving the protected party during the term of the order;
   2. Orders requiring the surrender or return of passports, visas, or other travel or identity documents necessary to prevent removal of the protected party;
   3. Orders restraining third parties who knowingly aid or abet conduct enjoined under this division, to the extent permitted by law;
   4. Orders necessary to ensure that a person is not removed from school, or prevented from attending school, medical or mental health appointments, meetings with service providers or attorneys, or extracurricular activities;
   5. Orders necessary to prevent the transportation of a person outside the jurisdiction for purposes related to a forced marriage.

EXISTING LAW:

1. Establishes the Domestic Violence Protection Act (DVPA) setting forth procedural and substantive requirements for the issuance of a “protective order,” whether issued ex parte, after notice and hearing, or in a judgment, that enjoins specified acts of abuse, excluding a person from a dwelling, or enjoining other specified behavior. (Family Code Section 6200 et seq. All further statutory references are to the Family Code.)
2. States that the purpose of the DVPA is to prevent acts of domestic violence, abuse, and sexual abuse and to provide for a separation of the persons involved in the domestic violence for a period sufficient to enable these persons to seek a resolution of the causes of the violence. (Section 6220.)
3. Provides that a domestic violence restraining order (DVRO) may be issued to restrain a person, as specified, based on an affidavit or testimony and any additional information provided to the court that shows, to the satisfaction of the court, reasonable proof of a past act or acts of abuse. Specifies that a court may issue an order under this part based solely on the affidavit or testimony of the person requesting the restraining order. (Section 6300 (a).)
4. Defines “domestic violence” as abuse perpetrated against any of the following persons:
   1. A spouse or former spouse;
   2. A cohabitant or former cohabitant, as defined;
   3. A person with whom the respondent is having or has had a dating or engagement relationship;
   4. A person with whom the respondent has had a child, where the presumption applies that the male parent is the father of the child of the female parent;
   5. A child of a party or a child who is the subject of an action under the Uniform Parentage Act, where the presumption applies that the male parent is the father of the child to be protected;
   6. Any other person related by consanguinity or affinity within the second degree. (Section 6211.)
5. Authorizes a court to issue an order under the DVPA to restrain any person to prevent acts of domestic violence, if an affidavit or testimony and any additional information provided to the court shows, to the satisfaction of the court, reasonable proof of a past act or acts of abuse. Authorizes the court to issue an order under the DVPA based solely on the affidavit or testimony of the person requesting the restraining order. (Section 6300.)
6. Authorizes a court to issue an ex parte order enjoining a party from, among other actions, disturbing the peace of another party. (Section 6320.)
7. Authorizes the court to issue a number of orders after notice and a hearing, including: orders enjoining a party from molesting; attacking; striking; stalking; threatening; sexually assaulting; battering; credibly impersonating; falsely personating; harassing; telephoning; destroying personal property; contacting, either directly or indirectly, by mail or otherwise; coming within a specified distance of; or disturbing the peace of the other party, and, in the discretion of the court, on a showing of good cause, of other named family or household members; and granting the petitioner the exclusive care, possession, or control of any animal owned or controlled by the petitioner or respondent or a minor child residing in the residence or household. (Section 6340 (a).)
8. Authorizes a court to issue an order excluding a person from a dwelling if the court finds that physical or emotional harm would otherwise result to the other party, to a person under the care, custody, and control of the other party, or to a minor child of the parties or other party. (Section 6340 (c).)

FISCAL EFFECT: As currently in print this bill is keyed fiscal.

COMMENTS: Forced marriage, where one or both parties is compelled to enter into a marriage without consent, is an issue of global concern particularly impacting women and young girls from lower-income families. According to the United Nations Office on Drugs and Crime, children from poor families or who are in unstable situations, including those with uncertain immigration status, are more likely to face pressure to enter into an unwanted marriage. Once in such relationships, victims often endure additional emotional trauma and abuse, physical violence, and financial abuse. (Forced marriage and human trafficking: What you need to know, United Nations Office on Drugs and Crime available at: https://www.unodc.org/unodc/en/frontpage/2025/December/forced-marriage-and-human-trafficking_-what-you-need-to-know.html.) Forced marriages, which can be coordinated by other family members or non-family community members, may also involve isolating the victim or victims from their support networks. According to data provided by the proponents of the measure, victims of forced marriages are often taken across state and international borders, limiting the ability of California and United States authorities to intervene. Unfortunately, it seems California’s existing laws may have a blind spot with regard to the subject of forced marriages, leaving these survivors out in the cold. The author posits:

AB 2534 is a critical piece of legislation that will extend domestic violence protections for women and girls being forced into a marriage or survivors of forced marriages. Victims of forced marriage often experience abuse, isolation, financial control, surveillance, and immigration threats from the perpetrator and extended family. In these cases, the perpetrator does not act alone, and coercion is often reinforced by family members or community members.

While forced marriages are a crime under existing law, many victims find themselves in dangerous situations without protective measures. The ability to file a restraining order will empower young girls and women to take steps to protect themselves with confidence.

AB 2534 will ensure that those being forced into a marriage, or survivors of a forced marriage, can get a restraining order against their perpetrator and others aiding in this process. By adding forced marriage to the Domestic Violence Prevention Act, these women and young girls will be able to file a Domestic Violence Restraining Order to ensure their safety and protection from those forcing them into a nonconsensual marriage.

California’s marriage statutes. To establish a legally valid marriage Family Code Section 300 requires 1) the consent of both parties, 2) the issuance of a license issued by the county clerk and 3) solemnization. The statute additionally specifies that the license only becomes a valid marriage certificate once it is registered with the county recorder. The Family Code also requires both parties to be at least 18 years old in order to obtain a marriage license, subject to a very narrow exception requiring permission from the court. (Family Code Section 302 – 304.) The Domestic Violence Prevention Act (DVPA) allows people in qualifying relationships to seek a restraining order against another person to protect against harassing or abusive behavior. (Family Code Section 6200 et seq.) Finally, under California Penal Code Section 265, it is a crime to force one or more parties to marry against their will.

Unfortunately, California’s marriage-related statutes leave issues related to forced marriage unaddressed. First, in order to obtain relief under the Penal Code, a marriage must have already occurred. Additionally, while not explicit in the text of the statute, it seems that the provision only captures legally valid marriages. Not only does this foreclose relief to individuals who are not yet married, but also excludes victims of forced marriages that are conducted outside the judicial system from its jurisdiction. Finally, despite the “domestic” nature of a marriage, whether legal or not, victims of a forced marriage may not be able to obtain protection against those most involved in coordinating the unwanted union unless they are an immediate family member or the other party to the marriage.

In an effort to bolster protections for parties to forced marriages, this bill expands the DVPA to capture the unique circumstances created by forced marriages and clarify a path for survivors to obtain domestic violence restraining orders against any potential party to the coercion.

A brief summary of the role and procedures of domestic violence restraining orders. Like most restraining orders, DVROs usually take the form of “stay away” orders that ensure separation of the parties, at least for as long as it takes to appear in court or eliminate the threat of violence. Emergency protective orders and temporary restraining orders are issued ex parte – that is, based only upon the affidavit or testimony of the party seeking relief. A permanent restraining order, on the other hand, may be issued only after a hearing at which the respondent is free to attend and testify. Because of their inherently time-sensitive manner, requests for ex-parte orders are reviewed and, if approved, issued on the same day as requested, or the next business day at the latest. An ex parte order is typically short in duration and may then be followed by an order after hearing within 21 days of filing the underlying petition. In the time between an ex parte order and a hearing on the petition, the petitioner must provide the respondent with notice of the petition, and a copy of the ex parte order if issued. A petitioner can often request that the sheriff’s department provide this notice so as to not expose the petitioner to greater risk of harm. Once a restraining order has been issued, it is immediately entered into a law enforcement database and may be enforced.

How this measure incorporates forced marriage survivors into the DVPA. Section 4 of the bill requires the DVPA to be liberally construed to prevent forced marriage and related coercive conduct. The new section additionally prohibits relief from being denied on the basis that the conduct is claimed to be customary, religious, cultural, or lawful in another jurisdiction, or due to the passage of time alone. The Family Violence Appellate Project (FVAP), which has submitted a position of support if amended, raises concern that the requirement that the DVPA be liberally construed specifically to prevent forced marriage may inadvertently narrow the same requirement as applied to other forms of domestic violence already contemplated by the DVPA. Narrowing the scope of the DVPA in no way appears to be the intent of either the sponsors or the author and therefore the parties are encouraged to discuss this issue to clarify the language in question.

Definitions. As currently enacted, the DVPA defines “domestic violence” as abuse perpetrated against certain people including: a spouse or former spouse; a cohabitant or former cohabitant; a person in a current or former dating or engagement relationship; a person with whom someone has had a child; a child; or any other person of blood-relationship within the second degree.

Forced marriages pose a unique complication to petitions for DVROs because, while some forced marriages may involve parties who are related to one another in one of these ways, others may not. For example, the marriage may be coordinated by a member of the community to whom the party to the marriage is not related in any capacity. This person may be in a position to exert significant pressure and control on the party being forced into the marriage, but absent the familial relationship and despite the “domestic” nature of marriage, the court would likely have no jurisdiction to issue a DVRO. Nevertheless, by its nature as a forced marriage, it seems appropriate to allow people facing such threats to petition for a DVRO. Therefore, this bill would amend the definition of “domestic violence” to include abuse perpetrated against a party to a forced marriage or an attempted forced marriage.

To further incorporate forced marriages under the scope of the DVPA, this bill would also define “forced marriage” as a spousal relationship in which at least one person does not or cannot consent and are compelled to enter into the marriage, regardless of whether the marriage itself is legally valid.

Working in tandem these definitions would carve a clear path for people who have been, or are being, forced into an unwanted marriage to explicitly qualify for a domestic violence restraining order.

Definition of “coercive control” and “disturbing the peace.” Family Code Sections 6320 – 6327 provides guidelines and procedures for a court to issue an ex parte order. Section 6340 then allows a court to issue an order after a hearing on any of the same grounds authorized in the provisions guiding ex parte orders. (Family Code Section 6340.) Under Section 6320, a court may issue an ex parte order prohibiting the respondent from “disturbing the peace” of the petitioner. “Disturbing the peace” is further defined as “conduct, based on the totality of the circumstances, destroys the mental or emotional calm of the other party,” and further specified to include “coercive control, which is a pattern of behavior that in purpose or effect unreasonably interferes with a person’s free will and personal liberty.” (Family Code Section 6320 (c).) The statute then proceeds to give examples of coercive control, many of which may very well apply to situations involving forced marriage. However, survivors of forced marriages report that their experiences often fall outside the existing examples. Acknowledging this bill is proposing to expand the DVPA in a novel way and that more examples may therefore be helpful in the implementation of the changes, this provision would be modified to incorporate “interfering with, threatening, or attempting to prevent a party or witness from participating in court proceedings” as an example of “coercive control”.

Similarly, this bill proposes to further expand this section to specify that conduct that seeks to “compel, attempt to compel, prepare for, or facilitate a forced marriage” constitutes disturbing the peace of the petitioning party, and provides a number of examples.

Expanding the types of proof of abuse that may justify a DVRO. Existing law authorizes a court to issue an order to restrain a person based on an affidavit or testimony that shows, to the satisfaction of the court, reasonable proof of a past act or acts of abuse. (Family Code Section 6300 (a).) Family Code Section 6203 defines “abuse” as intentionally or recklessly causing or attempting to cause bodily injury; sexual assault; placing a person in reasonable apprehension of imminent serious bodily injury to that person or another; or engaging in any behavior that has been or could be enjoined in an ex parte order. Like the Act’s existing definitions, the language of this provision may not capture circumstances involving forced marriages. This bill would therefore likewise amend Family Code Section 6300 to allow a court to issue an order upon reasonable proof of prior instances of forced marriage or a credible risk of forced marriage occurring, regardless of whether a marriage actually occurred or would be legally valid in California.

Expanding the types of orders a judge may issue after a hearing on the petition. Finally, this bill proposes to expand the types of orders a judge can issue in a DVRO after a full hearing on the petition to reflect actions that may be appropriate to protect a party to a forced marriage. Reflecting experiences that victims of forced marriages commonly endure, this bill proposes to include the following as types of orders that a judge may issue in a DVRO: orders prohibiting the arrangement, solemnization, or facilitation of any marriage involving the protected party; orders requiring the surrender of passports or other forms of ID; orders necessary to ensure that a person is not removed from school or prevented from attending school, medical or mental health appointments, meetings with service providers or attorneys, or extracurricular activities; orders necessary to prevent transportation of a person outside of the court’s jurisdiction for reasons related to the forced marriage.

The bill would also authorize a court to issue “orders restraining third parties who knowingly aid or abet the conduct restricted by the DVRO, to the extent permitted by law.” This language reflects one of the unique aspects of a forced marriage in that it does not necessarily only involve the parties to be married, but also often includes larger communities and parties outside of the intended marriage.

While they have not registered an official position with the Committee, the Judicial Council has raised concerns to Committee staff about this provision. The Judicial Council’s concern, which centers on existing statutory notice requirements and due process issues, appears to be echoed by the Family Violence Appellate Project (FVAP). The note is well taken, as existing law does require that a respondent receive notice of the proceedings before the hearing on the petition. Arguably the final clause in the existing subparagraph (“to the extent permitted by law”) captures this notice requirement already. Nonetheless, the author may wish to consider a modest amendment to clarify that a court may issue an order restraining named third parties who knowingly aid or abet the conduct restricted by the DVRO.

The Family Violence Appellate Project raises four additional concerns about the bill as it is currently in print. It appears that the concerns can largely be attributed to a disagreement in interpretation and thus may be easily addressed with some clarifying language. For example, it is likely not the author or sponsor’s intent to prohibit a party seeking a DVRO from ever marrying again, a concern that FVAP raises about the language modifying the types of orders a judge may issue. Neither would it be reasonable to assume that the bill’s proponents wish to limit the liberal interpretation of the DVPA to only cases involving forced marriages. Therefore, it seems that some continued conversations are in order and likely to result in a favorable conclusion for all stakeholders.

ARGUMENTS IN SUPPORT: This bill is sponsored by the Family Violence Law Center, Tahirih Justice Center, and Choose Your Path Foundation. It enjoys additional support from a number of domestic violence prevention organizations, family law-focused organizations, Planned Parenthood Affiliates of California, and the Women’s Foundation California. The Family Violence Appellate Project has submitted a position of support if amended. In support of the bill, Family Violence Law Center writes:

This critical legislation addresses a dangerous gap in California’s protection of survivors by explicitly recognizing forced marriage as a form of abuse under the Domestic Violence Prevention Act (DVPA).

[…]

Forced marriage is a serious violation of human rights that often involves physical violence, sexual assault, and confinement. Without the specific protections provided by AB 2534, many survivors are left without a clear legal pathway to prevent these harms before they occur. The need for this bill is underscored by several alarming data points:

● A Pervasive but Hidden Crisis: Between 2009 and 2011, the Tahirih Justice Center– a sponsor of this bill– received reports of nearly 3,000 cases of forced marriage or the risk of forced marriage in the United States.1 Many of these cases involved minors and young adults who were unable to access traditional legal remedies.

● The Threat of International Abduction: Forced marriage often involves "vacationing" survivors to other countries where they have fewer legal rights. According to the U.S. Department of State, once a survivor is taken across international borders, the ability of the U.S. government to intervene is severely limited. AB 2534 provides the preemptive, emergency authority needed to order the surrender of travel documents, stopping this abduction before it begins.

● Coercive Control and Overlapping Abuse: Research indicates that forced marriage is rarely an isolated incident; it is almost always accompanied by coercive control, including financial abuse, physical threats, and reproductive coercion. Under current California law, the DVPA does not explicitly list forced marriage as a basis for a Domestic Violence Restraining Order (DVRO), making it difficult for courts to provide comprehensive relief.

● Safety Upon Separation: Data shows that separation is the most dangerous time for victims of domestic abuse. For those attempting to flee a forced marriage, this risk is heightened by the involvement of extended family or community actors who may aid in the coercion.

AB 2534 provides survivors with a robust "shield" by allowing the court to prohibit third parties from facilitating a marriage and ensuring that a survivor is not removed from school or essential services as a means of punishment or control. California must join other leading states in providing clear, actionable legal protections for those at risk of being forced into a marriage against their will. We urge your support for this life-saving measure.

REGISTERED SUPPORT / OPPOSITION:

Support

Choose Your Path (CYP) Foundation (co-sponsor)

Family Violence Law Center (co-sponsor)

Tahirih Justice Center (co-sponsor)

Building Futures
Family Reunification Equity & Empowerment (F.R.E.E.)
Gender Justice LA
Love Never Fails
Maitri Bay Area
Messaging for Success
Planned Parenthood Affiliates of California

Strong Hearted Native Women’s Coalition, Inc.
Women's Foundation California

Support if Amended

Family Violence Appellate Project

Opposition

None on file

Analysis Prepared by: Manuela Boucher-de la Cadena / JUD. / (916) 319-2334