a modification but rather as an explanation of why the court was signing a protective order that appeared to contradict its own findings in the custody case. But when it placed its oral decision of the custody issues on the record in March 2016, the court explained that its intent was to modify and not ''reinstate' the protective order's domestic violence findings. We therefore review it as a substantive modification rather thaq an explanatory comment. 7 . Crystal writes in her brief that she “does not challenge th[e] trial court’s jurisdiction and ability to independently decide whether she established by a preponderance of the evidence that Charles committed two or more crimes of domestic violence against her for custody purposes.” See Morris v. Horn, 219 P.3d 198, 208 (Alaska 2009) (<HOLDING>). 8 . See AS 22.15.100(9)(A) (giving
holding that children are often physically assaulted or witness violence against one of their parents and may suffer deep and lasting emotional harm from victimization and from exposure to family violence consequently a family law judge should take domestic violence into account when making an award of temporary eustodyt based upon a recognition that it is clear that where domestic violence is present it should be considered when determining parental fitness holding that previous domestic violence finding did not have res judicata effect in proceeding to modify visitation because domestic violence and visitation modification proceedings are different causes of action holding south carolina crime of criminal domestic violence of a high and aggravated nature was categorically a crime of violence under ussg  4b121 because its lesserincluded offense criminal domestic violence fell entirely within  4b12ls force clause holding as relevant in a murder case a history of domestic violence involving defendant and his victim holding that plaintiff was precluded under principles of res judicata and collateral estoppel from relitigating in proceedings under prevention of domestic violence act allegations which had been decided adversely to her in earlier hearing